summary of responses october 2018 - bracknell forest · plan consultation (published october 2018)...

SUMMARY OF RESPONSES (MAIN ISSUES) TO DRAFT BRACKNELL FOREST LOCALPLAN CONSULTATION (PUBLISHED OCTOBER 2018)

This document contains a summary of the main issues raised in response to the Draft Bracknell Forest Local Plan consultation which took place between 8 February and 26 March 2018.

Comments are structured by the chapter headings and policies contained within the Draft Local Plan.

Against each section of the Draft Plan, comments are organised in three sections: • Statutory consultees and duty to co-operate bodies • Residents and other local organisations/groups • Developers/promoters of sites

Within each comments section, the respondent is identified by either the surname of an individual, or the name of the group/organisation. ‘ID’ reference numbers are also included, which relate to the reference number of the comments generated by our consultation database.

Sections of the document can be accessed using the contents pages below.

Individuals/groups/organisations can also be searched within the document by using ‘Control’ and ‘F’ keys on a keyboard, which will bring up a search window.

Contents Responses to Section: 1 Introduction, and 2 Context………………………………………7

Responses to Sections: 3.1 Vision and 3.2. Objectives…………………………………..12

Responses to Section: 4.1 and Policy LP1 Sustainable Development Principles……16

Responses to Section: 5.1. Overarching Spatial Strategy………………………………..19

Responses to Section: 6.1. Provision of Housing/Policy LP2…………………………...24

Responses to Section: 6.2. Residential/mixed use development/Policy LP3…………40 General comments about proposed development (not site specific)........................ 40 Site BIN1 – Land north of Tilehurst Lane..................................................................... 49 Site BIN5 – Land south of Forest Road and east of Cheney Close............................ 56 Site BIN6 – Land south of Emmets Park and east of Cressex Close ......................... 75 Site BIN11 – Popes Farm, Murrell Hill Farm................................................................. 99 Site BRA6 – Bracknell and Wokingham College, Wick Hill, Sandy Lane................. 101 Site BRA7 – Town Square, The Ring.......................................................................... 102

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Site BRA13 – Coopers Hill Youth and Community Centre, Crowthorne Road North ...................................................................................................................................... 103 Site SAND5 – Land east of Wokingham Road, and south of Dukes Ride (Derby Field) ...................................................................................................................................... 104 Site WAR9 – Land north of Herschel Grange ............................................................ 107 Site WAR10 – land north of Newhurst Gardens ........................................................ 119 Site WINK15 – Whitegates, Mushroom Castle, Chavey Down Road ........................ 137 Site WINK20 – Former Landfill Site, London Road ................................................... 139 Site WINK34 – land to the rear of Forest View and Oriana, Longhill Road, and west of Fern Bungalow (extension of site allocated through Policy SA3 of the SALP) .. 142 Site BIN7 – Land south of Foxley Lane and west of Whitehouse Farm Cottage,Murrell Hill Lane .......................................................................................................... 143 Site BIN10 – Popes Manor, Murrell Hill Lane ............................................................. 148 Site BIN12 – Land south of London Road (Eastern Field) ........................................ 150 Site BRA11 – Bus Depot (Coldborough House), Market Street ................................ 151 Site BRA12 – Former Bus Depot, Market Street ........................................................ 152 Site BRA14 – Jubilee Gardens and British Legion Club, The Ring.......................... 153 Site BRA15 – land east of Station Way and North of Church Road (Southern Gateway) ...................................................................................................................... 155 Comments about proposed development (omission sites, and new sites promotedthrough the consultation) ........................................................................................... 156

Responses to Section: 6.3/Policy LP4. Land at the Hideout and Beaufort Park, Nine Mile Ride, Bracknell…………………………………………………………………………….185

Responses to Section: 6.4/Policy LP5. Land south of London Road, east of Bog Lane and west of Swinley Road (Whitmoor Forest), Bracknell……………………………….195

Responses to Section: 6.5/Policy LP6. Land at Winkfield Row……………………….213

Responses to Section: 6.6/Policy LP7. Land at Hayley Green………………………..250

Responses to Section: 6.7. Other forms of residential accommodation……………271

Responses to Section: 7. Economic Development/Policy LP8 (sites allocated for economic development)……………………………………………………………………….273

Responses to Section: 8. Strategic Infrastructure (including transport) / Policy LP9 (strategic and local infrastructure)…………………………………………………………..276

Responses to Chapter 9: Introduction……………………………………………………...284

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Responses to Chapter 10: Sustainable Development – General ……………………...285 Responses to Policy LP10 (Presumption in favour of sustainable development) .. 287

Responses to Chapter 11: Development Affecting the Countryside and Green Belt – General……………………………………………………………………………………………288

Responses to Policy LP11 (Protection of Countryside) ........................................... 289 Responses to Policy LP12 (landscape character and strategic gaps) .................... 294 Responses to Policy LP13 (rural workers dwellings) ............................................... 298 Responses to Policy LP14 (occupancy conditions) ................................................. 299 Responses to Policy LP15 (equestrian uses)............................................................ 300 Responses to Policy LP16 (Green Belt) ..................................................................... 301 Responses to Policy LP17 (developed sites in the Green Belt: Syngenta) ............. 304

Responses to Chapter 12: Character and Design………………………………………...306 Responses to Policy LP18 (Design) ........................................................................... 306 Responses to Policy LP19 (Tall Buildings)................................................................ 312 Responses to Policy LP20 (Internal Residential Space Standards)......................... 314

Responses to Chapter 13: Housing…………………………………………………………319 Responses to Policy LP21 (Protection of Existing Housing Stock and Land) ........ 319 Responses to Policy LP22 (Housing for Older People) ............................................ 320 Responses to Policy LP23 (Self Build and Custom Built Housing) ......................... 323 Responses to Policy LP24 (Affordable Housing) ...................................................... 329 Responses to Policy LP25 (Housing Mix – Tenure Size and Accessibility) ............ 336 Responses to Policy LP26 (Travelling Populations) ................................................. 341

Responses to Chapter 14: Employment Areas – General……………………………….342 Responses to Policy LP27 (Employment Areas)....................................................... 343

...................................................................................................................................... 344 Responses to Policy LP28 (Employment Development outside Employment Areas)

Responses to Policy LP29 (Smaller Businesses) ..................................................... 345 Responses to Policy LP30 (Development in Bracknell Town Centre) ..................... 346 Responses to Policy LP31 (Out of Centre Development) ......................................... 347

Responses to Chapter 15: Local Retail and Community Uses – General……………348 Responses to Policy LP32 (Changes of use within defined Retail Centres) ........... 349 Responses to Policy LP33 (Advertisements and Shop Fronts) ............................... 352 Responses to Policy LP34 (Protection of community facilities and services)........ 353

Responses to Chapter 16: Historic Environment – General……………………………355

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Responses to Policy LP35 (Protection and Enhancement of the Historic Environment) ............................................................................................................... 356

Responses to Chapter 17: Natural Environment – General……………………………..361 Responses to Policy LP36 (Biodiversity)................................................................... 363

...................................................................................................................................... 371 Responses to Policy LP37 (Designated Nature Conservation and Geological Sites)

Responses to Policy LP38 (Green Infrastructure)..................................................... 374 Responses to Policy LP39 (Thames Basin Heaths Special Protection Area) ......... 376

Responses to Chapter 18: Climate Change and Environmental Sustainability – General……………………………………………………………………………………………379

Responses to Policy LP40 (Flood Risk)..................................................................... 380 Responses to Policy LP41 (Sustainable Drainage Systems) ................................... 382 Responses to Policy LP42 (Addressing Climate Change through Renewable Energyand Sustainable Construction)................................................................................... 384 Responses to Policy LP43 (Pollution and Hazards).................................................. 386 Responses to Policy LP44 (Development of Land Potentially affected bycontamination)............................................................................................................. 388

Responses to Chapter 19: Transport. General…………………………………………….389 Responses to Policy LP45 (Strategic Transport Principles) .................................... 390 Responses to Policy LP46 (Assessing, Minimising and Mitigating the Transport Impacts of Development) ............................................................................................ 394 Responses to Policy LP47 (Transport Infrastructure Provision) ............................. 395 Responses to Policy LP48 (Travel Plans) .................................................................. 397 Responses to Policy LP49 (Parking).......................................................................... 398

Responses to Chapter 20: Local Infrastructure and Facilities – General…………….400 Responses to Policy LP50 (Play, Open Space and Sports Provision)..................... 401 Responses to Policy LP51 (Standards for Open Space of Public Value) ................ 403

Responses to Appendix 1:……………………………………………………………………..405 Policy LP2 – Housing Trajectory ................................................................................ 405 Policy LP3 and LP8 – Site Allocations Overview Maps ............................................ 406 Site Profiles for sites listed in Policy LP3 (excluding sites within the Bracknell TownCentre* and sites covered by policies LP8), Policy LP17, Policy LP27, Policy LP32 ...................................................................................................................................... 408

Responses to Appendix 2 Existing Policies to be Replaced by the Bracknell ForestLocal Plan………………………………………………………………………………………...411

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Responses to Appendix 3 Glossary and Abbreviations…………………………………412

Responses to the overall Plan (not section specific) and other matters/comments/proposed changes to the Draft Bracknell Forest Local Plan…...413

Comments on Evidence Base………………………………………………………………...427

(GTAA) (arc4, October 2017)....................................................................................... 442

CLP/Ev/3b: Economic Development Needs Assessment (EDNA) (NLP, October 2016)

General Comments...................................................................................................... 427 LP/Ev/1b: Sustainability Appraisal ............................................................................. 428 CLP/Ev/2b: Bracknell Forest Gypsy and Traveller Accommodation Assessment

CLP/Ev/2c: Strategic Housing Market Assessment (SHMA) (GL Hearn, February 2016) ............................................................................................................................. 443 CLP/Ev/2d: Western Berkshire Housing Market Area Strategic Planning Framework(GL Hearn, February 2016).......................................................................................... 444 CLP/Ev/2e: Housing Background Paper (BFC, February 2018)................................ 445 CLP/Ev/3a: Functional Economic Market Area (FEMA) (NLP, February 2016) ........ 447

...................................................................................................................................... 448 CLP/Ev/3c: Retail and Commercial Leisure Study (GVA, April 2017) ...................... 449

CLP/Ev/4c: Water Cycle Study (JBA Consulting, December 2017) .......................... 453

December 2017) ........................................................................................................... 456

CLP/Ev/5c: Green Belt Review (Amec, June 2015).................................................... 463

CLP/Ev/7a: Archaeological Appraisal of Sites (Berkshire Archaeology, April 2017)

CLP/Ev/3d: Approach to Employment Areas Assessment (BFC, February 2018) .. 450 CLP/Ev/4a: Open Space and Sports Study (BFC/Sarah Moore Consultant, August 2017) ............................................................................................................................. 451 CLP/Ev/4b: Playing Pitch Strategy (BFC/4 Global).................................................... 452

CLP/Ev/4d: Bracknell Forest Local Plan – Approach to Transport Modelling (BFC,January 2018) .............................................................................................................. 455 LP/Ev/4e: Bracknell Forest Local Plan, Infrastructure Delivery Plan 2017 (BFC,

LP/Ev/4f: Draft Transport Accessibility Assessment of Potential Sites (BFC,February 2018) ............................................................................................................. 460 CLP/Ev/5a: Landscape Character Assessment (LCA) (LUC, September 2015)....... 461 CLP/Ev/5b: Landscape Recommendations Report (LUC, September 2015) ........... 462

LP/Ev/5d: Green Belt Village Assessment (BFC, February 2018) ............................ 464 LP/Ev/5e: Landscape Sensitivity Appraisal of Potential Housing and EmploymentSites in Bracknell Forest (LUC, February 2018) ........................................................ 465 CLP/Ev/6: Design SPD ................................................................................................ 467

...................................................................................................................................... 468 LP/Ev/7b: Historic Environment Assessment of Sites (LUC, February 2018) ......... 469 CLP/Ev/8a: Ecology Surveys (John Wenman Ecological Consultancy, September,2017) ............................................................................................................................. 470

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LP/Ev/8b: Ecology Surveys – Addendum Report (John Wenman EcologicalConsultancy, February 2018)...................................................................................... 472

February 2018) ............................................................................................................. 474 CLP/Ev/9c: Draft Sequential Test (BFC, February 2018)........................................... 475

CLP/Ev/10c: Site Selection Methodology (BFC, June 2017) ..................................... 478

(SHELAA), Part 1: Methodology (BFC, June 2017).................................................... 479

CLP/Ev/10g: Draft Habitats Regulations Assessment (HRA) (BFC, January 2018) 481

CLP/Ev/9a: Green Infrastructure Review (TVERC, September 2017) ....................... 473 LP/Ev/9b: Level 1 Strategic Flood Risk Assessment (SFRA) (JBA Consulting,

CLP/Ev/10a: Duty to Co-operate Framework ............................................................. 476 CLP/Ev/10b: Regulation 18 Consultation Statement (Scope of the CLP) ................ 477

CLP/Ev/10d: Strategic Housing and Economic Land Availability Assessment

CLP/Ev/10e: Strategic Housing and Economic Land Availability Assessment(SHELAA), Viability Assessment (BNP Paribas Real Estate, June 2017) ................ 480

CLP/Ev/10h: Strategic Housing and Economic Land Availability Assessment (SHELAA), Part 2: Results (BFC, December 2017) .................................................... 483 Other: Missing evidence base .................................................................................... 484

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Responses to Section: 1 Introduction, and 2 Context


RESPONDENT (NAME/ORGANISATION & OBJECTIVE REFERENCE ID)

COMMENTS RECEIVED (SUMMARY OF MAIN ISSUES RAISED)

STATUTORY CONSULTEE/DUTY TO CO-OPERATE BODY

Binfield Parish Council (ID248) Welcomes the introduction and context, however would like to see more emphasis placed on the Infrastructure Development Plan (Draft 2017). Can this plan be added to the list of documents comprising the Development Plan and the future Development Plan thus giving more weight to the infrastructure required to support development in the area?

Environment Agency (ID1523) Welcome and support a number of the objectives, issues and policies but have significant concerns relating to some areas – flood risk, biodiversity and infrastructure provision. Without EA suggested amendments, EA are likely to find proposed submission document unsound.

Environment Agency (ID1256) Rivers and lakes should be included within Map 3 “Bracknell Forest Constraints Map” as they are an important key constraint to development, providing wildlife corridors and natural flood management. It would also be more helpful/concise to combine Map 3 with existing policies map for a comprehensive picture.

Environment Agency (ID1256) Encouraged to see flood risk highlighted as an area where development should be avoided. Previously advised functional floodplain should be mentioned as a constraint, indicating essential infrastructure (identified in the IDP) and water compatible development is appropriate.

Historic England (ID772) Point out that definition of “historic environment” in the NPPF is wide-ranging, encompassing more than just the built environment and that HE has produced a revised Good Practice Advice Note: 1: “The Historic Environment in Local Plans”, available on the Historic England website.

Para 2.5 The Council should have regard to a range of historic environment evidence, not just that relating to housing sites.

Portrait of Bracknell Forest: Concern about lack of reference to the historic environment as required by paragraphs 126 and 157 of the NPPF. Reference should be made to designated heritage assets.

Paragraph 2.17: Query lack of reference to the environmental (and economic) characteristics of the Borough, including those of the historic environment.

Paragraph 2.19: Query reference to “features associated with the historic environment” as being a constraint. HE and NPPF, use the term “heritage assets”. Heritage assets may also provide opportunities as well as constraints.

Warfield Parish Council (ID665) Have no comments on the introduction. Following proposed changes to NPPF expect to see any appropriate changes reflected in final

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plan. WPC advise it may be appropriate to consult with Town and Parish Council’s.

Warfield Parish Council (ID665) Evidence base comprehensive, but advise caution about proposed housing trajectory based on experience of delivery of Warfield SALP area.

Warfield Parish Council (ID665) Consider not listing SANG as an existing planning constraint an oversight given the legal agreements and protections afforded to it.

Warfield Parish Council (ID665) Comments on Neighbourhood Plans noted. Sandhurst Town Council (ID1106)

Section 1- introduction.

There is no statement of purpose such as:

“The purpose of this local plan is to detail: i The strategy which guides the content of this local plan; ii The Borough Councils objectives and land use policies for the control of development, the protection of heritage, community identity and areas of natural and environmental significance which support the strategy; and iii the proposals which would help to secure the implementation of the strategy.

Sandhurst Town Council (ID1106)

The overarching strategy is at section 5, this should be in the first section and the plan and evidence should follow the strategy.


Section 2 – context.

No mention of the importance each (separate) community places on its own unique identify. This should be made clear early on in the plan.


Para, 2.19. There is no reference of the gaps between settlements, which is not supported. Policy LP12 states “development within strategic gaps will only be supported where…”, is weakened by the fact there are no strategic gaps identified on the constraints map.

RESIDENTS AND OTHER LOCAL ORGANISATIONS/GROUPS

Campbell (ID45) Para. 2.3. Does not consider the Plan to be aspirational. There is no specific commitment to return house prices to their historic values, and makes homes affordable. There is a housing crisis, recognised by the Government but not in the Plan, and was first defined in RPG9 (Regional guidance for the South East), and also referred to in other published documents (documents listed include: Foreword by R.H.Clarke, Director of Highways and Planning Towards 2000; Shaping the Future Berkshire. Berkshire County Council Dept.of Highways and Planning; January 1990; Campbell Gordon, Prosperity at Risk, June 1992; Foreword by Prime Minister in February 2017 White Paper, Fixing our broken housing market; DCLG; Foreword in the same white paper by the Secretary of State for Communities and Local Government; February 2017; and Nick Boles, MP and previous housing Minister; Housing, Planning and Green Belt debate House of Commons, 6 February 2018).

Campbell (ID45) Para. 2.11 & 2.12 (cross boundary issues and partnership working). Reference is made to evidence being prepared with other Berkshire

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Councils. Comments made that there ought to be recognition that unaffordable house prices locally are due to past misguided local plan policies, and there is little reference in the Plan that house prices are due to previous restricted supply (reference also made to comments made by MPs at the February 2018 housing debate). If more unprotected land within Bracknell is needed on which to build new homes, answer lies outside of the Borough boundaries.

Murphy (ID621) Para. 2.9. Notes that retained policies of the SALP 2013 are part of the future development plan. Unbuilt allocations comprise around 65% of total allocations in the draft BFLP. The draft HRA only assesses new allocations.

Murphy (ID621) Duty to co-operate does not include both European sites, only Thames Basin Heaths SPA and not Windsor Forest and Great Park SAC.

Murphy (ID621) Para. 2.12. Some of the evidence base is provisional e.g. ecology, flood risk and HRA. Assessing suitability and allocating sites on this basis is not sound.

Murphy (ID621) Map 3 (page 15). Inconsistent with depiction of European sites. Only the part of the Windsor SAC that lies within Bracknell Forest is shown, but the complete area of the Thames Basin Heaths SPA that lies partly outside the Bracknell Forest Area is shown.

Wallen (ID818) Para. 2.15. Isn’t the Lexicon 2017 just Phase 1 of the redevelopment?

Glennerster (ID1160) Text too complicated.

Campaign to Protect Rural England Berkshire Branch (ID1530)

Consider there to be insufficient evidence of co-ordination (with regard to the duty to co-operate) across the boundary between Bracknell Forest Council and Royal Borough of Windsor and Maidenhead in relation to proposed development and allocations. Concerned regarding the amount of development proposed by both Council’s, which should be the subject of a study to assess the total impact of development on local communities and infrastructure.

DEVELOPERS/PROMOTERS OF SITES

Broadmoor Hospital (ID238) Para 2.9. Supports Site Allocations Local Plan Policy SA4 is a retained policy in the new Local Plan.

Broadmoor Hospital (ID238) Para 2.19. Comments made on the Draft Thames Basin Heaths SPA SPD should be considered as part of this Local Plan consultation.

Broadmoor Hospital (ID238) Para 2.19 2nd bullet is not fully consistent with the Habitats Directive, the guidance of the JSPB Delivery Framework or Policy NRM6 which recognises that developments within the 400m of the SPA will be assessed on their own merits and exceptional circumstances may apply where mitigation is capable of protecting the integrity of the SPA. Para 2.19 should be amended to reflect this and avoid confusion that the SPA designation imposes an absolute limit on residential development in certain areas.

Hall & Woodhouse Ltd (ID1206) There are a number of references and objectives relating to retaining community facilities as part of social infrastructure, but the emphasis is more on protection of existing facilities, rather than encouraging and supporting new provision in tandem with new residential.

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Pegasus Group for the Whitaker Family (ID1498-1507)

Para 2.11 refers to the duty to Co-operate Framework which is dated February 2016; as a result information within it regards co-operation or otherwise from relevant bodies is not up to date.

Para 2.11 refers to annual reporting in a monitoring report. The 2015-16 Annual Monitoring Report published in January 2017, refers to the Berkshire Unitary Authorities instructing GL Hearn to establish housing market areas and objective assessment of need.

It is not clear if all other local authorities are supportive of the emerging plan, in particular the quantum of housing within it. It is also not clear whether authorities beyond the housing market area, but with a relationship with the Borough in terms of housing and employment generation, agree with the approach adopted.

Other Berkshire authorities, in particular Reading and Slough, have considerable housing need, which may need to be shared with other Authorities. Overspill from London is likely to add to the pressure for Bracknell to take more housing numbers in the future.

Bewley Homes (ID1466) Para. 2.11 refers to the Duty Co-operate Framework dated February 2016 - information within it, with regards co-operation or otherwise from relevant bodies is not up to date.

House Builders Federation (OD1279)

Note that the Council has worked collaboratively in preparing evidence on housing needs. Does not disagree with the HMA (covering West Berkshire, Reading Borough, Wokingham Borough and Bracknell Forest Councils), but notes it will be important for the Council to continue to work with other HMAs given the complex patterns of migration and commuting.

Notes the preparation of the West of Berkshire Spatial Planning Framework, and the Memorandum of Understanding between the authorities, but the issue of unmet need within Reading has not been addressed. Should be resolved before the local plan is submitted for examination.

Gladman (ID1581) Information will be required to accompany the version of the Plan that is published under Regulation 19 with regard to how the Council is discharging its duty to cooperate. In particular, how the four authorities within the Western Berkshire Housing Market Area, together with the Local Enterprise Partnership, are working on cross boundary issues relating to economic development and housing needs.

Gladman (ID1038) Para. 2.20/2.21 – the Local Plan should provide guidance for any future Neighbourhood Plan, to ensure they fulfil strategic and spatial policies of the Local Plan.

Turley on behalf of Bloor Notes and supports the principle of the preparation of the West of Homes Ltd (ID1426), Knight Berkshire Spatial Framework. However, have concerns regarding and Alfred Homes (ID1442) the co-operation with authorities to the east (i.e. Windsor

Maidenhead and Slough), in relation to strategic housing matters. Interconnected matters concerned distribution of unmet need in Buckinghamshire has duty to co-operate implications for Bracknell

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Forest. The Draft Plan needs to be supported by more robust evidence of co-operation and cross-boundary planning, in order than duty to co-operation obligations are demonstrably met.

Turley on behalf of Berkeley Notes the preparation of the of the West Berkshire Spatial Planning Strategic Land Ltd (ID1465) Framework and the Memorandum of Understanding agreed between

the West Berkshire HMA authorities. However, as noted within the Draft Comprehensive Local Plan (DCLP), the issue of unmet needs in Reading are not being addressed.

Para. 6.7 of the draft Plan notes that Reading’s residual needs may no longer be an issue given the lower objectively assessed need suggested by the emerging standard methodology. Disagree with this statement as Reading’s OAN is driven by the need to support its economic growth expectations rather than its demographic projections and market signals, a key principle that is likely to remain even if the standard methodology is introduced. Recently Draft PPG (page 26) indicates the outcome of the standard methodology should be considered as a minimum. The Plan should therefore be looking to demonstrate Bracknell’s ability to sustainably accommodate its reasonable share of Reading’s residual housing needs.

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Responses to Sections: 3.1 Vision and 3.2. Objectives





Binfield Parish Council (ID249), Warfield Parish Council (ID666)

Supports the policy, vision and objectives as presented.

Environment Agency (ID1257) Welcome and support the overall vision particularly protecting and enhancing areas of natural assets, biodiversity, the causes of climate change and prevention of flooding and pollution.

Environment Agency (ID1257) Paragraph 3.2 refers to protecting the natural environment commensurate with development needs, appearing to undervalue the natural environment in favour of development and is at odds with the statement (page 18) referring to respecting, protecting and enhancing the environment.

Environment Agency (ID1257) Paragraph 3.2 Objective, I as previously advised, should also refer to blue infrastructure.

Historic England (ID773) The Vision: Welcome statement in the Vision section that “development will have protected and enhanced……historic assets”. HE and NPPF use the term “heritage assets”. Need a standalone commitment to the conservation and enhancement of the historic environment/heritage assets.

Objectives: Query Objective B - “commensurate with meeting our development needs to ensure that the Borough’s valued natural and historic environment …as paragraph 14 of the NPPF makes it clear that local plans should meet objectively assessed needs unless “any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole; or specific policies in this Framework indicate development should be restricted”. Also refers to Footnote 9.


Para. 4 of Vision. What if a community doesn’t want to develop a local Plan?


Request deletion of the sentence: “Any impacts of development on designated areas such as the Thames Basin Heath SPA and the Green Belt will be mitigated”, as implies that development in these areas will be allowed. Such areas must have strong defensible policies that are not undermined by the acceptance that there will be circumstances where these policies will be relaxed.


Objectives: Suggest either B or F includes reference to the maintenance of gaps between communities.


Campbell (ID46) Para. 3.1 (vision). Household formation rates should be considered. Impact of an ageing population is not mentioned. The Vision ignores future threats such as overspill from Reading, Slough, London and Surrey, and what will happen after the plan period. Where will new housing go over 2036?

Campbell (ID47) Para. 3.2 (objectives). Difficult to see how the Council will deliver

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the objectives whilst control of the location and timings of housing projects remains with private sector housing and developers. Council must retake control of location and timings of supply to protect open countryside and meet growth pressures. Objective G, how will this policy achieve a sustainable long term solution without council leadership and direct ownership?

Rogers (ID321, 358) No issues with section, but the document does not support Objective F (strong communities) by removal of the strategic gap between Binfield/Bracknell and Crowthorne/Bracknell.

Murphy (ID622) Objective B. Either replace Thames Basins Heaths Special Protection Area with “European Sites” or add “and Windsor Forest and Great Park Special Area of Conservation”.

Wallen (ID819) Objectives – where would meeting the needs of the growing population come into the objectives?

Tuffley (ID984), Tuffley (ID1000)

Unclear what is meant by sustainable (Vision 3.1).

Collings (ID 1066, 1089) Vision: The Plan should also aim to minimise the impact of development on existing residents.

Collings (ID1066, 1089) Objectives: some of these are aspirational, but not wholly achievable in practice.

Hobbs (ID1091) Vision: amount of housing planned is not consistent with providing a great place to live and work in a sustainable environment.

Hobbs (ID1091) Transport: impact of number of homes does not properly provide for a sustainable transport system. For most, the only choice is travel by car.

Jennings (ID1170) Evidence suggest that insufficient priority is given to protect/enhance existing assets. Essential that existing settlements are maintained and protected from inappropriate development.

Neill (ID1331) There is no link to Corporate Objectives. Contrary to Vision, the Town Centre as so far shown a lack of awareness for community identity, local distinctiveness and historic assets.

Jennings (ID1174) 3.2 - Recent evidence suggests that insufficient priority is given to (B) Protect/enhance existing assets. Economic growth should be driven by productivity/efficiency, not ever increasing numbers of people. Small communities are strong communities and it is essential that existing settlements are maintained and protected from inappropriate development.

BBOWT (ID1215-1219) Objective B The stated objective for Policy LP36 is to “Protect / enhance existing assets”. This fails to mention the creation of new biodiversity assets (i.e. habitat creation), which is one of the key environmental objectives of the NPPF.

The NPPF clearly states in paragraph 114 that “Local planning authorities should: ● set out a strategic approach in their Local Plans, planning positively for the creation, protection, enhancement and management of networks of biodiversity and green infrastructure;”

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BBOWT Recommendation NPPF compliant wording for the Objective would be “Protect / enhance existing assets and creation of new assets” (additional proposed text is underlined).

(Comment duplicated in Policy LP36 Biodiversity) Winkfield Row Residents The Plan vision is highly aspirational, but presumptuous. The claims Association (ID968) are not evidenced in the Plan, therefore are meaningless. Viability

and deliverability are not demonstrated. Greater detail on key issues such as health, education and mitigation of traffic are required.


Deloitte Real Estate for Welcome that the overall vision and objectives of the draft plan have Bracknell Regeneration been prepared with consideration to The Lexicon (reference made to Partnership (The Lexicon) paras. 2.15, 5.15, 14.4.6, and 15.1.2). (ID868) Deloitte Real Estate for Welcome the inclusion of protection and continued expansion of Bracknell Regeneration Bracknell Town Centre as one of the nine key objectives of the Draft Partnership (The Lexicon) Plan. BRP are keen to continue to invest in the wider regeneration (ID870) of Bracknell Town Centre. Hall and Woodhouse Ltd (ID1208)

There are a number of references and objectives relating to retaining community facilities as part of social infrastructure, but the emphasis is more on protection of existing facilities, rather than encouraging and supporting new provision in tandem with new residential. Para 4.4 makes no reference to community facilities, which is a clear omission.

The Crown Estate (ID1414) Support Vision (including intention to allocate small, medium and large sites on both brownfield and greenfield land) and Objectives A and D.

Concerned that whilst there is a specific objective in relation to economic growth, there is no corresponding objective specifically in relation to residential need. New objective required covering residential development resulting in cascade of objectives. Retain Objective D but remove reference to affordable housing.

Gladman (ID1037) Generally supports the intentions of the Vision. An appropriate suite of positively framed local plan policies will be required to ensure the vision can be achieved.

Gladman (ID1036) Welcomes the objectives, in particular A, B, C and F. Persimmon Homes North Consider the vision lacks sufficient emphasis on residential London (ID1399) development. Only touches upon supporting the growing population

through small, medium and large site allocations, which raises concern over Bracknell’s commitment to identifying new sites in order to contribute towards the housing supply trajectory. The Vision therefore should include greater focus on delivering existing site allocations, including the existing allocation at Amen Corner South, as well as identifying future sites suitable for residential development.

Barton Willmore on behalf of Syngenta support the Vision that by 2034, the Borough will have

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Syngenta (ID1545) “continued to grow sustainably”, however, to achieve this vision, Syngenta advocate a number of changes to the Draft Local Plan Policies (see specific comments on proposed policies).

The Council state in the Vision that the “needs of business will have been supported, with the protection of key employment areas, which accommodate some of the Borough’s key employers.” Syngenta support this objective, in addition to the Council’s visionary support for “new and innovative business models.” The Sustainable Science Community at Jealott’s Hill, would be such an innovative business model, aiming to co-locate compatible businesses to gain synergistic benefits within a new Science and Innovation Park as part of a sustainable new community which would enable those employed at the site to walk or cycle to work.

Boyer on behalf of Luff Luff support BFC’s reference in the Local Plan Vision summary to Developments (ID1325) the inclusion of small and medium sites as part of the allocations and

support the reference to the use of both brownfield and greenfield land. The principle of including smaller sites within Local Plans is also in line with the aims of the draft NPPF consultation document (March 2018).

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Responses to Section: 4.1 and Policy LP1 Sustainable Development Principles





Binfield Parish Council (ID250) Supports para 4.1. Binfield Parish Council (ID250) Development that reduces the carbon footprint of new dwellings

through the use of reusable energy, water and improved insulation should be actively encouraged. Policy LP1 should be amended to reflect this. This will also give greater emphasis to para 4.5.

Historic England (ID774) Policy LP1: Welcome and support criterion iv) of Policy LP1 but would prefer it to refer to the “significance” of heritage assets.

Paragraph 4.5: Welcome and support the second bullet point Environment Agency (ID1258) Welcome reference to protecting and enhancing the environment in

Policy LP1 and responding to climate change in relation to flooding. However, recommend amending point iv to include reference to extending green infrastructure network, particularly along river corridors. This ensures policy reflects Objective B.

Environment Agency (ID1258) Pleased to see essential infrastructure included in Policy LP1. Advised to link this to Policy LP9 as this refers to development protecting existing, providing new or enhancing existing infrastructure.

Environment Agency (ID1258) Provision of waste water infrastructure is essential to protecting the environment by preventing pollution. Recommend including text in paragraph 4.5 reflecting this, especially as Policy LP9 references utilities infrastructure. This will ensure policy comprehensively reflects Objective I.

Warfield Parish Council (ID667) Generally supportive of sustainable development principles and policy LP1.

Winkfield Parish Council (ID 569)

There is no directive on how many of the nine principles should be met for the proposed developments to be sustainable.


Campbell (ID48) Until the Council finds the leadership to deliver its new responsibilities (set by the last coalition government), fulfilling the objectives will be handicapped. Justification for passing responsibility to local councils for housing supply is not apparent in the plan. A new mind set is required. The plan is based on an old failed model. Vision, timeframe, spatial horizon, governance and funding vision do not match the expectations of the Government. No single development proposal is likely to deliver benefits equally in terms of economic, social and environmental impacts. Building bits of housing on the edge of built up areas is the opposite of sustainable development.

Murphy (ID623) Para. 4.5 (environmental). Not consistent with allocation of Policies LP6 and LP7. Bullet 1: BFC has no design policy to support block/estate building behind/adjacent to small rural linear settlements. Robust design policy needed to respect character and form of existing villages.

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Wallen (ID820) Policy LP10 building in the more rural north and north east parishes of Warfield and Winkfield does not help with points viii) and ix), as these areas need cars to reach major shops and transport links.

Para. 4.5 (last bullet point) – SANGS are not always compatible with wildlife, for example Larks Hill and Cabbage Hill have/will lose larks due to the presence of dogs.

Hobbs (ID1092) LP1(iii) how is it possible to maintain local character and landscape when an area is changed from rural to urban?

Hobbs (ID1092) LP1(viii) & (ix) Amount of infrastructure required to deal with increased traffic flows will change the character of the area.

Jennings (ID1171) Bracknell is a low unemployment area and the Plan should not be seeking to increase the number of local jobs as this will create additional demand for housing.

Warfield Environment Group (ID1189)

Development in the north of the Borough does not align with points viii) & ix).


Para. 4.5 – human friendly SANGs are not always compatible with wildlife (e.g. Larks Hill and Cabbage Hill which have/will lose larks due to the presence of dogs).

Neill (ID1332) Para. 4.3 – propose addition of economic incentives for independent and charitable retailers.

Neill (ID1332) Para. 4.5 - propose a stronger commitment to environmental concerns by changing 'This might include giving consideration...' to 'This will include giving consideration…'

Jennings (ID1174) Sites War9 & War10 do not meet the criteria of a sustainable development. Specifically, substantial new housing would not enhance and maintain local character (iii); would not protect and enhance the natural environment (iv); would not be located so as to reduce travel (viii); and would be totally reliant on private cars (ix).

Jennings (ID1174) Para 4.3 - Bracknell is a low unemployment area and the BFLP should not be seeking to increase the number of local jobs as this will stimulate additional demand for housing. Economic development should be prioritised in the regions (North & West) where it is most needed.


Support Policy LP1.


Para. 4.5 should include reference to ensuring the unique quality and character of each community.


Broadmoor Hospital (ID240) Supports Site Allocations Local Plan Policy SA4 as a retained policy in the new Local Plan. Commitment to bringing forward a mixed use development with a planning application in 2019/2020. However, the redevelopment strategy is under review and a number of options are being considered including uses of the retained buildings and potential to deliver additional housing, care home and community facilities. The emerging outcomes will be discussed in due course.

Hall & Woodhouse Ltd (ID1210) There are a number of references and objectives relating to retaining community facilities as part of social infrastructure, but the emphasis

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is more on protection of existing facilities, rather than encouraging and supporting new provision in tandem with new residential. Para 4.4 makes no reference to community facilities, which is a clear omission.

Gladman (ID1035) Concerns regarding the proposed policy in relation to the consistency with the presumption of sustainable development set out in national policy.

The policy begins with “proposal for development will be permitted that”. This appears to mean only grant permission for development proposals that fulfil each of the points covered in the list, or could be taken as a direction to refuse consent for proposals that fail to meet one or more of the principles set out in the list.

Social, economic and environmental dimensions of sustainable development need to be considered on a case by case basis. There are likely to be circumstances where harm is identified against one aspect, which has the potential to be outweighed by wider sustainability benefits that could be fulfilled by granting planning permission. The balance will need to tilted, should there be a lack of 5 year housing land supply.

Wording of the principles set out in the policy appear to be inconsistent with national policy, e.g. the NPPF does not set a principle that the natural environment and heritage assets and their settings will be protected and enhanced.

Any local policy that sets out sustainable development principles should reflect the significant weight to be placed on the need to support economic growth through the planning system (as highlighted in para. 19 of the NPPF).

Barton Willmore on behalf of Syngenta (ID1546)

Support of sustainable development principles. Support parts ii), v) and vi).

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Responses to Section: 5.1. Overarching Spatial Strategy





Binfield Parish Council (ID251) Para 5.5. The West of Berkshire Spatial Framework (December 2016) identified opportunities for development across borough boundaries including the one between Binfield and Wokingham. Broadly agrees that, if opportunities for development were to arise from sites adjoining or crossing this boundary, then provision should be made across the boundary for infrastructure improvements.

Binfield Parish Council (ID251) Para 5.5. Supports the strategy that development should take place in urban centres as far as possible.

Binfield Parish Council (ID251) Para 5.5. Strongly oppose any developments within the strategic gap between Binfield and Wokingham that reduces the gap or the appearance of it. The Binfield Landscape Character Assessment section 4.1.12 recommends that the gap be maintained in order to conserve the open and rural character to the settlement of Binfield.

Binfield Parish Council (ID251) Supports development on brownfield sites in the borough. These sites should be brought forward for redevelopment before considering development on greenfield sites. Green and open spaces are important to the quality of life of people in the Borough. Once they are gone, they are gone.

Royal Borough of Windsor and Maidenhead (ID1371)

Noted that Chapter 5 of the Draft Plan does not include a key diagram or spatial strategy policy.

Warfield Parish Council (ID668) Notes overarching spatial strategy. Bracknell Town Council (ID434) Para. 5.18. The opening of the Lexicon is welcomed, together with

varied/local employment, and access through provision of appropriate infrastructure. There should be reference to green spaces within the overarching spatial strategy (which are greatly valued by residents).


Suggest this section should follow the introduction, with the vision/objectives included, or following directly.


Para. 5.9. No clear commitment to maintenance of gaps between settlements, which should be included.


Paras. 5.23 and 5.25. Protection of Green Belt supported.


No strategic commitment to ensuring health and wellbeing of residents. Whilst referenced in section 4, there is no reference in the strategy. Changing demographic in the Borough needs to be recognised in terms of ageing population and the need that this will place on provision of related housing, the need for retirement/care homes, and the health care centres proposed in the Frimley Health Integrated Care System.


No strategic commitment to ensuring that policies such as use class do not impede the delivery of care homes with adequate parking (such as integrated care facility/retirement complexes that might otherwise be refused because of locational issues).

The section needs to include a statement as follows:

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“The LPA will be tolerant of the mix of use classes with regard to the delivery of health and care proposals outside town centre or settlement locations.”


Campbell (ID49) Reference is made to the West Berkshire Spatial Framework (December 2016) being a welcome start, and shows the Council is seeking to fulfil its duty to co-operate with some, not all of its neighbours. However, the framework contains no long term vision beyond 2036. Reference also made to the Framework containing a major spatial error. Much of the new build is in open countryside, dependant on a consortium of land owners, who should make such decisions, and who can deliver sustainable housing solutions (reference made to the ‘Grazeley project’).

The Plan should look to 2088, a long spatial options timeframe will enable all unprotected land in the Thames Valley to be assessed for future development suitability.

Fullerton (ID350, 351) Plan does not address how individual and currently self contained villages will be maintained. Character of the area is defined by a series of smaller villages dotted around larger towns, such as Bracknell and Ascot. How can they be sure that building on land between villages will not happen. The proposals are the first step towards eradicating village nature of the area.

Rogers (ID359) Cross border co-operation e.g. with Wokingham should not be considered a new concept. Attempts in past to set up a cross border forum (The Triangle Forum), recommend this is resurrected.

Sites spanning the administrative boundary between the areas of Bracknell, Binfield, Crowthorne and Wokingham were submitted by land owners as a result of the ‘call of sites’ exercise, to identify whether cross boundary sites could bring benefits of scale which could not be maximised through effective joint working. This section implies that duty to co-operate between Wokingham and Bracknell has not been effective.

Murphy (ID624) Para. 5.8. Only the SPA is mentioned. Replace with “European Sites” or add “Windsor Forest and Great Park SAC”.


Unclear what is meant by ‘overarching’ and ‘spatial strategy’. Suggests clearer language should be used.

Hobbs (ID1093) Para. 5.11 states it is important to maintain identify and integrity of smaller settlements, not possible with larger development proposed such as Hayley Green.

Glennerster (ID1150), Glennerster (ID1165)

Unclear what is meant by ‘over arching’ and ‘spatial strategy’.

Jennings (ID1172) Para. 5.7, by developing office and industrial floor space, the demand for housing will become a self fulfilling prophecy.

Jennings (ID1172) Para 5.11. Not just important to maintain identity and integrity of smaller settlements, it is essential.

Jennings (ID1172) Para.5.23. Land outside of the settlement should not be considered

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for development until all available land within the existing boundary has been fully utilised.

Jennings (ID1172) Para. 5.29. Plantations (such as Swinley Forest) should be treated as previously developed land and sacrificed before greenfield land.

Jennings (ID1172) Para. 5.31. Some smaller settlements aren’t being extended, they are being encircled. Resulting urban sprawl should be prevented.

Neill (ID1333) Para 5.14/5.15. Propose setting targets for units/floorspace designated for independent and charitable retailers.

Neill (ID1333) Para. 5.26. What will the effect of new development within Winkfield have on adjacent Green Belt.

Neill (ID1333) Para. 5.27. Infilling in the Green Belt should be ruled out. Neill (ID1333) Para. 5.34. There is no link to the five directional policies. DEVELOPERS/PROMOTERS OF SITES

Tingene Parks Ltd (ID368/369), Bracknell Land Ltd (ID380)

Agree with para. 5.23 that a significant proportion of new development will be needed on sites outside of defined settlements, if objectively assessed needs to be met.

Support para. 5.29 that heavy reliance on greenfield land is required to meet growth needs.

Support para. 5.31, that urban extensions are require to Bracknell Town and Crowthorne together with smaller settlements.

Broadmoor Hospital (ID239) Para 5.28 is not consistent with Policy NRM6 or the legal tests of the Habitats Directive. Recognise that developments within 400m of the SPA will be assessed on their own merits and exceptional circumstances may apply where mitigation is capable of protecting the integrity of the SPA and there are further legal tests in the Habitats Directive that allow for plans and projects to be approved as a derogation under article 6(4). Paragraph 5.28 should be amended to reflect this and any suggestion or implication that the exclusion zone is absolute is contrary to the legal position


Support para 5.31 which concludes urban extensions are required to Bracknell Town, Crowthorne and some smaller settlements. This dispersed approach provides scope to meet some needs where they arise and provides a variety of sites (including some smaller sites) in line with emerging national policy.

Previously Council relied too much on larger strategic sites that take much longer to bring forward. Delays caused by ownership disputes, infrastructure delivery etc have led to Council failing to maintain a five year housing supply for many years.

Proposed approach with a small number of larger sites and many smaller sites spread across the Borough, much more likely to deliver a robust housing land supply.

The Crown Estate (ID1416) Welcome the recognition that development needs will not be met within existing settlement boundaries or previously developed land. Support references to urban extensions of Bracknell Town. Support reference in Sustainability Assessment to the proposed Spatial

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Strategy being the most sustainable option Alfred Homes (ID1445) Concerned that a ‘Settlement Hierarchy’ is not proposed. Plan

simply seeks to concentrate most growth in Bracknell. Does not therefore fully evaluate the relative sustainability of settlements. Proposed approach is ‘adhoc’ and derived from anecdotal evidence. Does not ensure a portfolio of sites that can deliver in different markets.

Spatial strategy is not positively prepared, justified or consistent with national policy.

Persimmon Homes North Development within existing settlements - Towns and villages. The London (ID1400) plan recognises that the principal setting is Bracknell Town, yet the

potential to meet future growth in this area is limited by the small number of sites which have been promoted, therefore Bracknell Town has limited scope to accommodate growth. Crowthorne and Sandhurst are identified as sustainable settlements, but the Plan confirms no sites were allocated in these areas. Outside of these urban areas there are a number of village and hamlets, but future growth is likely to be limited to small scale opportunities. Therefore it is clear that future growth and development needs cannot be met in existing settlements, which raises concern with Bracknell’s ability to achieve sustainable development.

Development outside settlements. The Plan acknowledges that a significant proportion of new development will ned to take place outside of settlement boundaries. The Plan recognises that the sites identified in eth SHELAA with greatest potential were Warfield and Winkfield. Raises concerns that the Plan cannot meet future development needs on sustainable sites.

Green Belt. Notes that the potential for future development in the Green Belt is limited.

Other land in the countryside. Notes the heavy reliance on green field land is required to help meet growth needs, with urban extensions proposed to Bracknell Town , Crowthorne and some smaller settlements.

The Plan is supported by a Sustainability Appraisal (February 2018). The SA considers the allocation of sites in the countryside and concludes that allocating a mix of different sized sites would be most appropriate. However, it does not go further than this to include an assessment of sites in the countryside and does not therefore demonstrate that growth can be sustainably achieved in the Borough over the plan period. The failure to undertake a sustainability appraisal which demonstrates that sustainable growth can be achieved results in the Plan not being positively prepared and being found unsound. (Also summarised under evidence base).

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Turley on behalf of Bloor Concerns regarding the lack of a settlement hierarchy, therefore the Homes Ltd (ID1428), Knight Plan does not fully evaluate the relative sustainability of settlements and Alfred Homes (ID1445) within the Borough. Consequently no robust underlying rationale for

the delivery strategy and allocation of sites.

(Bloor Homes rep also refers to the Plans seeks to concentrate most growth at Bracknell, and therefore fails to properly consider how sustainable development can be accommodated in other sustainable settlements within the Borough. Sandhurst highlighted as an example of a sustainable settlement (transport facilities including a train station, services, amenities, employment) yet no allocations are proposed. In recent years only a site at Alford Close has been allocated. Do not consider this approach to be sound.)

Turley on behalf of Berkeley Strategic Land Ltd (ID1467)

Support the identification of Bracknell as the most sustainable settlement in the Borough.


Concern that the Council, against a need (para. 5.7) of 348,520 sqm of B Class employment floorspace (identified as the need within the EDNA) have only allocated 34,100 sqm.

Evident from the significant shortfall in employment land provision that the Council has been unable to source sufficient land on alternative non-Green Belt sites. Therefore, consideration should be given to sites within the Green Belt which could meet this need, where development would have the least impact on the character of the wider Green Belt, such as Jealott’s Hill.

Boyer on behalf of Luff Luff support the inclusion of allocations within towns and villages Developments (ID1326) within the Borough.

Support draft paragraph 5.11. Binfield is well served by local facilities including 3 churches, a community hall, a library, several shops, pubs, restaurants, takeaways and cafes, a primary school and regular bus routes. Binfield will also be shortly served by the Blue Mountain Learning Village which will provide an all-through school as well as community use of the recreation and sports facilities.

Additional recreational facilities will also be delivered shortly on Land West of Wood Lane, which gained Reserved Matters consent in 2017 for a Golf Entertainment Centre (planning application ref. 17/00031/REM).

Future residents of Bin5 and Bin6 will therefore benefit from a range of local services and facilities, meaning this is a sustainable location for future residential development.

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Responses to Section: 6.1. Provision of Housing/Policy LP2





Surrey Heath (ID109) Acknowledges that the Draft Plan seeks to meet an Objectively Assessed Need (OAN) of 12,060 new homes over an 18 year period from 2016- 2034. Officers are satisfied that BFC and its partner authorities within the Western Berkshire Housing Market Area (HMA) have agreed to work collaboratively to consider how to meet housing need within their HMA, and are not seeking to address any of their OAN figure outside of this area.

Chiltern District Council and South Bucks District Council (ID155)

Comments relate to duty-to-cooperate and soundness of evidence base – emphasise willingness to discuss the issues raised. Reference to the duty to co-operate framework (February 2016), which identifies housing a strategic matter, and refers to the Strategic Housing Market Assessment commissioned by the Berkshire Authorities. Chiltern and South Bucks District Councils continue to have significant concerns that a fundamental element of the Draft Local Plan evidence base – namely the Berkshire Strategic Housing Market Assessment by GL Hearn – does not provide a sound basis for plan-making. The study identifies a Western and Eastern Housing Market Area (HMA), (Bracknell forming part of the Western HMA, and South Bucks being part of the Eastern HMA). The framework refers to the overlap between the two HMAs and that co-operation is needed with authorities of the Eastern HMA.

Consider that the duty to co-operate documentation accompanying the Draft Plan fails to meet the requirements of the Localism Act 2011, for the following reasons, with respect to South Bucks and Chiltern District Councils (SB&C):

• BFC has failed to record a key duty to co-operate issue with SB&C, and indicate that this remains unresolved. This relates to the inappropriate definition of the HMA geography and strong functional relationships between the Eastern and Western HMAs. (Reference is made to the following, October 2015 South Bucks drew attention to the conflict between the emerging HMAs and the emerging HMA commissioned by Buckinghamshire Authorities. Also in October 2015 SB&C wrote to relevant duty to co-operate organisation (including BFC) to reiterate they were considering preparing a joint Local Plan. On the basis of undertaking a joint Local Plan, evidence commissioned by the Buckinghamshire authorities confirmed that South Bucks District formed part of a best-fit HMA comprising the four Buckinghamshire authorities, and there is a single HMA comprising the six Berkshire authorities – a draft report was sent to BFC and other organisations for comment in October 2015. BFC duty to co-operate documentation fails to record the fact that South Bucks has never agreed the housing need figures identified in the Eastern HMA.

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• BFC has failed to progress a Memorandum of Understanding (MoU) with SB&C despite repeated requested to the six Berkshire authorities (which date back to 2015).

• BFC does not appear to have published the May 2017 MoU between the Berkshire Local Authorities in the Western Berkshire and Eastern Berkshire & South Bucks HMA (which relates to the objectively assessed need for additional housing). (Publication of this by Reading Borough Council in November 2017 was the first time it was shared with SB&C. Comments made that SB&C were not aware of the preparation of the document, not invited to participate, not informed. Exclusion of SB&C is a fundamental failing under the duty to co-operate).

• The MoU undermines Berkshire evidence base on market geography by confirming the six Berkshire authorities have agreed to work together to meet full objectively assessed need for housing.

• The duty to co-operate monitoring report (Table 3.1) identifies relevant duty to co-operate bodies as ‘Berkshire authorities’ and ‘other local authorities in adjoining housing market areas’, therefore SB&C are relevant authorities, yet there has been no joint working on the Berkshire Spatial Framework (also confirmed by the Bracknell Forest draft Plan (para. 5.4) which refers to joint working between the four authorities in the Western Berkshire HMA and the Thames Valley LEP. No clear evidence to show pro-active or on-going approach across administrative boundaries (including providing for unmet housing need originating from Slough in respect of Green Belt policy.

• The SB&C Local Plan evidence defined the functional HMA for Buckinghamshire Authorities, and where relevant surrounding areas. South Bucks is split between two functional areas, partly within a Berkshire-wide HMA and partly within a Buckinghamshire HMA. The evidence goes on to apply functional HMA on a best-fit basis to provide a practical platform for plan making. The Berkshire SHMA (GL Hearn, 2016) does not define functional HMAs for defines HMAs on a best-fit basis in order to provide a platform for plan making.

• The best-fit approach of both local plans’ evidence bases does not and cannot change the functioning HMAs affecting Buckinghamshire and Berkshire. SB&C do not agree with the Berkshire best-fit approach of using district boundaries to define HMA – it is not an appropriate way to provide a platform for plan making, given there is a joint plan being prepared by SB&C. The emerging approach for a joint plan was shared in October 2015, four months before the GL Hearn best-fit approach was finalised and published.

• The GL Hearn report is considered to be out of date, as key base data has changed.

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• SB&C do not agreed with the Berkshire decision to define two best-fit areas, and not a sound basis for planning to meet Berkshire’s needs in a sustainable way.

• There are inconsistences between the housing and economic market geographies evidence (latter prepared by NLP, 2016), which concludes there are three functional economic areas across Berkshire (compared to two housing market areas), which supports the case for a single Berkshire-wide functional economic market area.

Binfield Parish Council (ID252) Para 6.8. Supports the provision of more homes in the country and the objectively assessed need. Local house prices support the premise that Bracknell should have its share of this provision. Particularly, supports the aim of providing more dwellings in the town centre.

Binfield Parish Council (ID252) Encouraged by the raised expectation for the percentage of affordable homes required. Provision needs to be made for truly affordable homes for first time buyers. House prices are so high that they are beyond the reach of many people. Young people with salaries ranging between £23,000 and £30,000 find it extremely difficult to raise enough of a deposit to bring down the price of a mortgage to manageable levels. A property with an asking price of £250,000 requires a salary of £30,000 to be multiplied by seven times plus a deposit of £30,000. Very few people can afford to do this. More creative ways should be found so that young people can continue to live and work in the Borough.

Binfield Parish Council (ID252) Para 6.15. Large windfall sites will usually be office blocks. Along Cain Road from the John Nike Hotel to Waterside Park are several prestigious office developments. Would like to see this area designated as a technology business park retained for offices with no housing provision allowed. The parish hosts offices of several large organisations, Dell, Hewlett Packard, Honda, Vodafone etc. and believes that several of these organisations would leave Bracknell if their area were to become mixed development areas leading to a net loss of jobs within the Borough.

Wokingham Borough Council (ID714)

Consider the use of the OAN as derived from the standardised methodology to be a reasonable approach, as long as further changes are made, if required by the final version of national policy.

WBC reiterates that it expects BFC to accommodate a proportion of RBC’s shortfall and that this should not just be met in the immediate ‘Greater Reading urban area’ but in the whole HMA. An ongoing dialogue is required between Reading, WBC, Bracknell Forest Council and West Berkshire Council.

WBC is supportive of the intention to promote higher density housing within Bracknell Town Centre.


WBC would encourage BFC to explore options for meeting the identified wider cultural need as set out in the GTAA through the plan making process rather than purely the PPTS need. An ongoing

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legal challenge to the lawfulness of the PPTS definition of Gypsies and Traveller is highlighted.

West Berks (ID1343) Acknowledge that there may be options to engage with adjoining Authorities regarding the need for transit accommodation for gypsy and travellers. WBDC needs to carry out further work on constraints and opportunities.

West Berks (ID1344) Support the Council’s intention to accommodate its housing needs (670 dpa).

Recognise that there is a need for additional office and industrial floorspace and that business and industrial floorspace has been lost, with a marginal increase in storage and distribution floorspace. Draw attention to Berkshire Memorandum of Understanding on Strategic Planning (MoU) (December 2013), which provides a framework for joint working

Warfield Parish Council (ID669) Accepts provision of more homes needed. Recognises that additional homes in LP2 includes sites in Warfield originally brought forward through SALP allocation in previous plans.


Where is the evidence the Government used to arrive at the assessment of the OAN? Evidence should be provided as this is a evidence based approach.


Figure 1 is Figure 2.

Winkfield Parish Council (ID569)

House prices are too high for many people. Future developments need to provide truly affordable homes for future generations, as the current ‘affordable’ housing remains too expensive.

Parish does not provide sufficient numbers of social/affordable/entry level housing and self-build opportunities

Single storey accommodation is rare in proposals but is essential for the large and growing older population; for themselves and to release their family housing for the next generation. Bungalows must be preserved and included in new developments.


Campbell (ID50) Plan ignores the threat of overspill (for example from Slough, London, Surrey, etc), this is not a sustainable way to proceed.

Existing barriers need to be overcome in order for Councils to deliver rapid big increases the Government wants: technical skills and governance issues (needs to be addressed by all the Thames Valley councils). Opposition from local residents, who have legitimate concerns, must be overcome also.

Reference made to ‘Readingstoke’ as a location within the Thames Valley which could accommodate a city on the scale of Milton Keynes.

Wallen (ID821) If WINK22 is discounted (does not look to be suitable site) this would remove 450 homes from the total, and there will not be enough homes to meet the 2,924 target.

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Richardson (ID857) The Council is keen to maintain a 5 year housing land supply (failure to do so recently). However, through some of the chosen allocations, it is likely that a shortage will continue to development due to lead-in time of larger sites. Para. 6.27 recognises the merit of smaller sites to help meet short term housing requirements, but does not make adequate provision.

Wallen (ID822) Cannot see how Bracknell Forest can be considered as part of Western Berkshire, it is more central Berkshire. Whilst it makes sense from an economic perspective, it seems to enable Reading to move their housing targets onto Wokingham and Bracknell. (In section 7.2 Bracknell is considered central Berkshire, so this is contradictory).

Murphy (ID786) Notes stress placed by national government for local planning authorities to rely on evidence to justify local housing need (para. 6.5). Further reflected in para. 6.21. Some of key evidence/ quoted documentation used to support Policy LP3 – Table 1 is questionable/ subjective; not ‘evidence’ as stated. Provides additional focussed points linked to LP7.

Collings (ID1067, 1089) In this section there is no mention of any assessment as to whether an additional 3,216 new dwellings in addition to the requirements of the existing SALP (11,139 new dwellings) will have such a detrimental impact on the area that parts of Bracknell Forest will no longer be a great and desirable location to live (as described in the Local Plan Vision – 3.1). Since only a very small proportion of the new dwellings allocated in the existing SALP (certainly in Warfield where I live) have been built/occupied it is impossible to accurately assess their impact on the local area especially in terms of infrastructure, and particularly roads. How can BFC do this until a greater proportion of the new dwellings have been built?

Jennings (ID1174, 1175) 6.6 - The OAN figure should be 635 dpa in line with the SHMA (11,430 total). 6.9 - The amount outstanding should be 11,430 - 9,136 = 2,294 (+10% = 2,524). 610 - 2,524 new dwellings would be significantly more deliverable and sustainable than 3,216.

Jennings (ID1174) 6.21 - Local communities are paying the price for developers being unable or unwilling to build on land that has already been allocated. This is creating a perverse incentive for developers and is clearly wrong.

Barry (ID1094) 6.4. Assessment of housing need takes no account of any factors other than populations. There is more need for affordable, not 4/5 bedrooms. What is affordable housing?

Neill (ID1334) 670 houses per annum will be deleterious to the living environment of existing residents.

Runham (ID495) Why keep building new unaffordable houses on green fields when there are hundreds of thousands of houses for sale within the borough and within a 10 mile radius of Bracknell and many offices are being converted.

Runham (ID495) MP Adam Afriyie says there is no top down figure for houses so why

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are new developments imposed on the Northern Parishes - even before many of them which have already been approved are built or sold? The Council needs to assess the damage that is being done to the environment and the lives of local people before anymore developments are approved.


Tingene Parks Ltd (ID370), Bracknell Land Ltd (ID381) Hewlett Packard Enterprise (ID907)

Support the Council’s decision (para. 6.6) to pursue the indicative objectively assessed need of 670 dwellings per annum, derived from government’s standard housing methodology. Support decision to have 2034 as the end date for the local plan (para. 6.6).

Thakeham Homes Ltd (ID597) Welcome the joint working within the HMA and publication of West of Berkshire Spatial Framework. Bracknell Forest should accommodate a proportionate amount of unmet housing need from Reading Borough given that it lies within the same Housing Market Area. The figure of 670dpa should therefore be increased.

Beaulieu Homes Southern (ID588)

Concerned that insufficient housing is being planned for, particularly in the early part of the plan period (will have implications for the Housing Delivery Test). Plan does not identify sufficient small sites to meet the requirement in Draft NPPF. Site at Scotlands House, Forest Road, Warfield would help address this issue.

Woolf Bond for Hodson Developments (ID916-922), JPP Land (ID914), Flavia Estates Ltd and JPP Land Ltd (ID 897)

Provision of Housing: The emerging Local Plan is considered unsound and must be amended as set out below to deliver sufficient homes to achieve the Government’s objectives regarding boosting housing supply.

a) The Local Plan period should be adjusted to cover April 2013 to March 2036. This will both ensure consistency with the other authorities in the western Berkshire HMA (whose emerging plans run to March 2036) and provide the minimum 15 years strategy post adoption in line with Government policy (adoption in October 2019 would require the plan to run until October 2034, or March 2035 to cover the annual monitoring period). Bringing forward the plan start date by three years will bring the plan in line with the evidence base. This plan period increases housing need from 12,060 homes to a minimum of 15,410 dwellings, resulting in the need to find additional sites for 1,597 dwellings;

b) Draft standardised methodology requirement must be updated to reflect 2017 medium affordability ratios once published on 26 April 2018;

c) The housing target should include allowances for unmet housing needs of neighbouring authorities i.e. Reading and Surrey Heath; and

d) The homes currently expected from three draft allocations and medium windfalls should be omitted as a source of housing land supply (no compelling evidence, 696 dwellings currently included).

Therefore, to ensure the emerging Local Plan is sound, sites for a total of 6,534 dwellings should be allocated (i.e. an additional 3,828

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dwellings than those currently proposed for allocation). Further increase is required to meet unmet need of neighbouring authorities and any increase resulting from changes in affordability.

Based on calculations:

Revised Plan target from April 2013 to March 2036 is 15,410 Less homes completed April 2013 to March 2017 (1,463) Less homes with planning permission at April 2017 (3,755) Less Adopted Local Plan allocations or sites pending a S106 (4,010)

Sub-Total 6,182 Plus flexibility allowance (10% of sub-total) 618 Revised sub-total of additional dwellings to be found in Local Plan

6,800 Deduct small windfalls potentially delivered 2017-36 (19 years at 14 dpa) (266) Final total of number of additional dwellings to be found 6,534

Objections to proposed allocations at sites WINK20, WINK22 and SAND5 (see relevant sections below) would increase the homes required by a further 945 dwellings.

Jones, R (ID601) Support Council’s commitment to meeting its full OAN during the Plan period with the provision of an additional 3,651 homes.

The supporting text identifies that of the 9,136 homes already identified, 3,199 homes are on large and medium sites which are allocations that do not have planning permission. There seems to be a significant reliance on previously allocated sites to be delivered. These sites were identified in the Site Allocations Development Plan which was adopted in 2013. As these sites have not come forward since the existing Plan was adopted, it is not considered justified to rely on these sites without robust analysis of their suitability and deliverability.

The draft Local Plan proposes nine sites with a capacity of 200+ dwellings – an allowance should be made for the fact that these sites require a longer time period for delivery, with far greater potential for delays and complications. The Borough already has a history of under delivery.

It’s critical that smaller suitable sites are identified, as per paragraph 69 of the draft NPPF.

Woolf Bond Planning for JPP Provision of Housing: Land & Neal (ID888), Warfield The emerging Local Plan is not currently considered sound and must Park (ID1294) be amended as set out below to deliver sufficient homes to achieve

the Government’s objectives regarding boosting housing supply.

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a) The Local Plan period should be adjusted to cover April 2013 to March 2036. This will both ensure consistency with the other authorities in the western Berkshire HMA (whose emerging plans run to March 2036) and provide the minimum 15 years strategy post adoption in line with Government policy (adoption in October 2019 would require the plan to run until October 2034, or March 2035 to cover the annual monitoring period). Bringing forward the plan start date by three years will bring the plan in line with the evidence base. This plan period increases housing need from 12,060 homes to a minimum of 15,410 dwellings, resulting in the need to find additional sites for 1,597 dwellings;

b) Draft standardised methodology requirement must be updated to reflect 2017 medium affordability ratios once published on 26 April 2018;

c) The housing target should include allowances for unmet housing needs of neighbouring authorities i.e. Reading and Surrey Heath; and

d) The homes currently expected from three draft allocations and medium windfalls should be omitted as a source of housing land supply (no compelling evidence, viability study from BNP Paribas suggests more than 25% not viable – conflict with LP24, 696 dwellings currently included).

Therefore, to ensure the emerging Local Plan is sound, sites for a total of 10,945 dwellings should be allocated (i.e. an additional 8,239 dwellings than those currently proposed for allocation). Further increase is required to meet unmet need of neighbouring authorities and any increase resulting from changes in affordability.

Based on calculations: Revised Plan target from April 2013 to March 2016 is 15,410 Less homes completed April 2013 to March 2017 Less homes with planning permission at April 2017

(1,463) (3,755)

Less sites allocated in adopted Plan or with resolution to grant subject to S106 (4,010)

Sub-Total 10,192

Plus flexibility allowance (10% of sub-total) 1,019 Revised sub-total of additional dwellings to be found in Local Plan

11,211 Deduct small windfalls potentially delivered 2017-36 (19 years at 14 dpa) (266) Final total of number of additional dwellings to be found 10,945

Objects to allocation of three sites – reduces allocation number to 2,706 dwellings; therefore further sites needed for 8,239 dwellings.

Objections to proposed allocations at sites WINK20, WINK22/LP5, LP6 and SAND5 (see relevant sections below) would increase the homes required by a further 945 dwellings.

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Pegasus Group for the Whitaker Para 6.1 to 6.21 – several assumptions re housing requirements and Family (ID1498-1507) supply are incorrect.

The SHMA for 2013-2036 identified objectively assessed need (OAN) of 635 dwellings per annum. The projection based figure is a number of years of low housing delivery; appropriate employment forecasts have not been used and overspill from other area (including London), were not taken into account. 635 is much too low; Council is correct not to use it.

Council has adopted the standard methodology approach (670 dwellings per annum); which is more appropriate, but still very low. It is part of government push to provide more housing and leads to a National figure of 266,000 dwellings per annum. This is still well short of the Government aspiration of 300,000 per annum. The 670 figure should be considered an absolute minimum, likely to increase in foreseeable future.

Note Bracknell has been extremely successful in creating jobs in recent years. At First Tuesday Club seminar on 6th March, Andrew Hunter, Director of Planning, Highways and Countryside stated the Borough had created 9,000 jobs in last 3 years (excluding jobs created by the Lexicon).

Unless significantly more housing is built in Bracknell in very near future, these workers will have to commute in; increasing traffic congestion, pollution and lowering quality of life. More housing is needed to match the economic success, adding to prosperity of the Borough.

Hall and Woodhouse Ltd (ID1212)

It is important that all of the sites, together with adjoining existing residential communities, are property provided with all necessary infrastructure, including community facilities such as public houses. In respect of smaller sites consideration should be given to ensuring that there are appropriate opportunities off-site so that cumulative increase can be taken into account.

Hall and Woodhouse Ltd (ID1212)

Sections 6.2/6.3 (Policies LP3-LP7) only broad brush references to community facilities. The Policies should include a clear policy expectation that the residential content will be developed alongside the provision of opportunities to provide or enhance the existing community facilities provision, including through the provision of new public houses.

Bewley Homes Plc (ID1321) 6.52. Reference is made to ‘caters for the needs of all people’. This is possibly a typo and should read ‘older’ people.

Bewley Homes Plc (ID1321) 6.53. States the estimated need for 1,026 units of specialised self-contained dwellings over the plan period 2016/17 and 2033/34,

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based on an average of current and national rates of provisions. Consider that emphasis is given to this figure being only an estimate based on the 2016 SHMA findings, and as such a flexible approach should be taken to ensure the Borough’s needs are met.

Bewley Homes Plc (ID1321) 6.55. Reference is made to a net increase of approx. 319 bed spaces in use class C2. This figure is only an estimated calculation.

Bewley Homes Plc (ID1321) 6.56. The Draft Plan states there is a sufficient supply of care homes. Reference is made to outstanding permissions for a further 60 bed spaces relating to the outline application (13/0575/OUT) at TRL, approved in January 2015. However, on review of the application, it appears that the details regarding what sector of care home provision will be catered for remains outstanding. Evidence base (Housing Background Paper, February 2018) also states that the number of bed spaces at Broadmoor Hospital site has still not been agreed. This puts into doubt the conclusion that it is not necessary to make further allocations for use class C2 in the Local Plan.

POPPI data referred to in the Housing Background Paper estimates ongoing demand from increasing number of people with dementia (1203 additional people, and 3003 with mobility problems) in Bracknell Forest between 2013-2036. This provision should be addressed in the draft Plan, including on a number of smaller sites which can be delivered more quickly alongside the care homes referred to in the Draft Plan.

Pegasus for Rumsey (ID1463) The assumed trajectory of homes being delivered at the Winkfield Row allocation (Figure 6) suggests delivery will not commence until 2028/29.

It is very likely that development on site will commence well in advance of this, with the delivery of homes feasible from 2021/22.

Crown Estate (ID1413) Supports the use of the Government’s Standardised Methodology and collaborative working plus total requirement.

Alfred Homes (ID1442) Support use of indicative housing figure but subject to change and does not take account of economic performance. Likely that the proposed approach will fail to properly address the housing pressures that will arise as a result of planned infrastructure investment and the expansion of Heathrow.

Do not agree that Reading’s unmet need could or will be met within the Greater Reading Urban Area – refer to Wokingham Borough Council’s representations to the Bracknell Draft Local Plan. Furthermore, lack of greenfield sites within Reading means it is highly unlikely to be able to meet its requirement for larger / family housing.

Also refer to issues with meeting unmet need in East of Berkshire

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HMA (shortfall of 6,000 – 8,000 dwellings in Slough and dispute with S Bucks shortfall should be met in South Bucks). Also refer to the reliance of the Buckinghamshire Authorities on Aylesbury Vale District Council to accommodate approximately 8,000 dwellings over and above its own housing need.

As Bracknell Forest and Wokingham Borough are less constrained, they may have to accommodate a quantum of the circulating unmet need arising within Buckinghamshire and the East of Berkshire HMAs. Plan needs to include additional suitable sites to provide greater flexibility than currently demonstrated. No provision for an early review is made.

Although the complex cross-boundary issues affecting Western Berkshire would have been more comprehensively addressed through a ‘joint local plan’, support the principle of the preparation of the West of Berkshire Spatial Framework.

The Council has consistently struggled to maintain the required housing land supply. Delivery of new dwellings has frequently fallen below the anticipated timings. No consideration is given to the implications of lapses in planning permissions.

Concerned about the emphasis placed on high density allocations within Bracknell Town Centre. Also timescales and capacities of these sites are too optimistic (fail to consider visual amenity, transport impact etc.). Some of the sites have existing occupants and are not readily available.

Also proposing to allocate a number of large, constrained sites elsewhere within the Borough – complex and take a long time to deliver.

Estimated capacity of certain sites seems to differ between the SHELAA and that set out in the Draft Sustainability Appraisal.

Bewley Homes (ID 1466) Although the SHMA was commissioned jointly, it’s not clear whether the other authorities are supportive of the approach to the amount of housing in the Local Plan. Also not clear whether Authorities which lie beyond the defined housing market area, but which have a relationship with the Borough in terms of housing and employment generation, are in agreement with the approach.

Concern is expressed regards the suggestion that the Council is unlikely to need to assist with Reading’s potential shortfall in housing due to the Government’s indicative assessment of housing need suggesting a lower figure for Reading. Such an approach does not allow for Reading increasing its figure beyond the standard methodology, to reflect their growth aspirations.

Consider the Council’s assumptions with regards to its requirements

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and supply to be incorrect - set out in separate Housing Evidence Base Paper.

House Builders Federation (ID1277)

Agree with Council’s decision to plan for an OAN based on the standard methodology.

Whilst comments not made on specific sites, highlight the importance of having realistic delivery expectations within allocations, to ensure deliverability of the plan across the plan period (particularly import where there is a reliance on strategic sites).

Amount of windfall across the plan relatively modest. Recommend that the Council considers the amount of windfall it expects to come forward from medium sites. Note a number of medium sites are proposed to be allowed, which in the past would have formed part of the windfall supply. If these types of sites are now allowed, windfall supply from such sites is likely to be lower.

Savills on behalf of Martin Grant Homes (ID815)

Support the approach outlined in Policy LP2 (although caution that the Government’s indicative assessment does not take account of economic growth, therefore this figure should be considered a minimum).

Para. 6.13 outlines that sites allocated through the previous Site Allocations Local Plan are to be saved - support this approach.

In relation to the SA9 allocation (Martin Grant Homes has an interest in land that falls within Warfield Area 3), consider the housing delivery trajectory to be realistic and achievable for Area 3. (Martin Grant Homes is working with Council and other parties to submit an outline application in 2018).

Gladman (ID1583) The objective assessment should identify the full need for housing before the Council consider undertaking any process of assessing the ability to deliver this figure (reference made to court cases: Solihull Metropolitan Borough Council v (1) Gallagher Homes Limited (2) Lioncourt Homes Limited.)

There is a need to consider market signals, as set out in the NPPF and PPG.

Footnote 9 of the NPPF, although not exhaustive is clear that local landscape designations, intrinsic value of the countryside, the character of areas, green gaps etc. are not specifically mentioned as constraints by the NPPF.

Gladman (ID1034) LP2 – Proposed housing requirements in the Government’s proposed reforms remain indicative.

Noted that a flexibility allowance of 10% is proposed, in reality that means a planned supply provides a flexibility allowance of less that 2%. Further contingencies required, and suggest a flexibility allowance of 20%, which is consistent with a number of recent local plans (such as Redcar and Cleveland, Derbyshire Dales, Stratford

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on Avon). Persimmon Homes North Agree with the proposal to plan for 670 dwellings per annum, in London (ID1401) accordance with the proposed formula for calculating OAN.

Reading Borough (within the same HMA as Bracknell Forest) may have a shortfall of housing across the plan period. Whilst it is noted that the Government’s indicative assessment indicates a lower OAN than previously used, the four authorities within the Western Berkshire HMA have agreed to work collaboratively to meet needs within the HMA (Western Berkshire Spatial Planning Framework). However, the Framework does not set out how the shortfall will be apportioned across the four authorities. There is no provision with the proposed housing provision for Bracknell to address this unmet housing need. Therefore, consider the Plan lacks sufficient assessment of scale on shortfall to be accommodated within Bracknell Forest, and in its current form, and policy LP2 does not meet the requirements of soundness as set out in para. 182 of the NPPF.

Barton Willmore on behalf of Concerned regarding the over reliance of windfall within the supply, Harrison Housing (ID1064) equating to 934 dwellings equating to c. 12% of the need for the

remainder of the plan period. Given the scale of sites being considered and allocated, many of the sites which would typically be expected to come forward as windfall will instead be allocated.

The Council has benefitted from a significant number of prior approvals office to residential conversions, which are not expected to continue with the imposition of an Article 4 directed, therefore future yields of windfalls will not be expected to continue, and should be reduced.

Given land values, and previous rates of delivery, sites which might be considered windfall will have already been delivered or have extant permission, therefore question whether the projected delivery rate is achievable.

Boyer on behalf W J Channing Support the figure adopted as the annual requirement. & Sons (Woking) Ltd (ID1380)

There is a substantial amount of housing that is required to be delivered throughout the plan period, the development strategy is based on a large proportion of the required housing being delivered on strategic sites, it is critical that these expectations are realistic. A regular review of the timescales determining the number of sites being delivered would allow for other potential sites in the Borough to come forward if needed, helping to fulfil the required supply of housing. This in turn would also make for a more robust Local Plan as it would demonstrate a flexibility and compliance with para. 14 of the NPPF.

Site at the Rough promoted as readily available and suitable (see comments on omission sites).

Turley on behalf of Bloor Support the approach to the housing requirement outlined in paras

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Homes Ltd (ID1427), Knight 6.4-6.6 of the Draft Plan. However caution the formula applied as and Alfred Homes (ID1442) the proposed methodology is subject to change and does not

currently account of economic performance and related uplifts in household formations/inward migration (notes the SHMA, para. 5.50 does not take account of such factors).

Therefore, likely that the proposed approach will fail to properly address the housing pressures that will arise as a result of planned infrastructure investment, including expansion of Heathrow.

In relation to unmet need from Reading, note that the standardised methodology suggests reading Borough will experience a decrease in need compared to the SHMA. However, regional-level infrastructure investments may further increase related housing and affordability, which will need to be addressed. Do not agree with para. 6.7 that all of Reading’s unmet nee could or will be met within the Greater Reading Urban Area.

Also raise concerns regarding unmet need from Slough and relationship with Buckinghamshire, and the unmet need from the East of Berkshire HMA , with potential ‘domino effect’ to Bracknell Forest and Wokingham Borough Councils.

The Plan needs to provide greater flexibility, and revised to include additional suitable housing sites. The Plan makes no provision for an early review to be triggered.

Turley on behalf of Bloor Despite the adoption of the Core Strategy and Site Allocations Local Homes Ltd (ID1427), Knight Plan, the Council has struggled to maintain the required housing and Alfred Homes (ID1442) land supply, and delivery of new dwellings has fallen short of

anticipated trajectories.

Many committed sites fail to come forward, the Draft Plan does not give a detailed consideration to the implication of lapsed permissions.

Windfall contributions are also anticipated to make a reasonable contribution to supply. However, note that as the Draft Plan proposes to allocate a greater number of smaller sites (compared to previous Plans), the amount of un-planned windfall provision might effectively be reduced when compared to historic trends.

(Bloor Homes rep also raises concerns raised on the delivery of a number of proposed sites within the Draft Plan which are included in relevant sections below).


Support the OAN based on the standard methodology. However, this should be used as a starting point for consideration of housing need, and be treated as a minimum requirement.

Barton Willmore on behalf of Willson Developments Ltd (ID944) and Syngenta (ID1547)

Barton Willmore have undertaken an assessment of Objectively Assessed Housing Need, which indicates 700-730 dwellings per annum, some 30-60 dwellings per annum higher than the housing

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http://consult.bracknell-forest.gov.uk/file/4928891





requirement figure of 670 as set out in the Draft Local Plan. This would mean a further 540-1,080 dwellings to meet the minimum requirements.

Consider the standard methodology set out in the Draft revised NPPF and PPG (March 2018) to hold little weight as only at consultation stage.

Concerns regarding the Berkshire Strategic Housing Market Assessment (SHMA) assumptions in terms of the number of jobs (322 per annum) which underpins the SHMA. Concerns supported on appeal in BFC (APP/R0335/W/17/3177088), where the Inspector support Barton Willmore’s approach.

Boyer on behalf of Luff The housing need figure anticipated by the 2016 Berkshire Strategic Developments (ID1327) Housing Market Assessment (SHMA) for Bracknell of 635 dwellings

per annum is set out in Chapter 6. Luff support the proposed use of the Objectively Assessed Need (OAN) as set out in the Government’s draft standardised methodology. This figure is slightly higher, at 670 dwellings per annum. Luff are supportive of Bracknell’s use of the higher figure with draft Policy LP2.

This approach is also in accordance with the draft NPPF. Housing demand in Bracknell Forest is high and the Borough have been under delivering for several years. There is therefore a need going forward to allocate and deliver a sufficient number of homes within the Borough.

Support the inclusion of “at least an additional 12,060 homes in Bracknell” within draft Policy LP2. The provision of housing should not be restricted to a maximum figure if there is an opportunity for sustainable development to meet local needs to be delivered. Luff are in agreement with the flexibility included within this policy.

Note the reference to the need to deal with a shortfall of 943 dwellings over the plan period for Reading Borough (within the same Housing Market area as Bracknell Forest). It is noted that the supporting text states “Reading Borough Council is keen that its unmet need is accommodated within the Greater Reading Urban Area”. However, it is not known at the current time whether all of this need can be accommodated within the Greater Reading Urban Area. Luff are therefore supportive of the flexibility within draft Policy LP2 to allow additional housing delivery if required and if possible.

Supportive of paragraph 6.12 which covers the inclusion within the draft Local Plan of sites that are retained Site Allocations Local Plan (SALP) allocations, such as Bin5 and Bin6.

Although Bin5 and Bin6 were allocated within the SALP, the number of dwellings to be provided on these sites is currently un-determined

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as the capacity within Policy SA7 will have been taken up by the Reserved Matters applications for Blue Mountain.

Supportive of the work the Council has undertaken to assess Bin5 and Bin6 as individual sites and their inclusion as allocations within the draft Local Plan

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Responses to Section: 6.2. Residential/mixed use development/Policy LP3. General comments about proposed development (not site specific)

Responses to Section: 6.2. Residential/mixed use development/Policy LP3

General comments about proposed development (not site specific)




Royal Berkshire Fire and Requests that all new developments where Fire Hydrants or EWS Rescue Service (ID149) (Emergency Water Supplies) are required, inclusion is made

as a planning condition and the builders pay and install these at their cost under CIL (Community Infrastructure Levy).

Binfield Parish Council (ID254) Many of the proposed sites include affordable housing. Any planning permissions granted on these sites should have conditions ensuring that the numbers of affordable dwellings proposed are built. If a developer wishes to develop a site and asks for planning permission with a certain number of affordable dwellings as well as providing other amenities to mitigate the impact of the development on current residents, the Borough Council should be asking for assurances that the developer can afford to discharge their obligations on the site prior to granting permission. The UK is the only country in the EU putting developer profitability before affordable housing and CIL/Section 106 provision.

Binfield Parish Council (ID254) The objectively assessed housing need, defined in paragraph 6.9, is lower than the number of units allocated in the plan. Except for Bin11, which has planning permission, all of the Binfield sites should be removed from the site allocations as the total number of dwellings proposed for Binfield will not materially affect the attainment of the total number of dwellings required, and the impacts on the infrastructure of the developments already agreed but yet to be delivered are, as yet, unknown. Without knowing the true impact of these developments on the existing, and already strained, road network agreeing further development is irresponsible and short-sighted

Binfield Parish Council (ID254) The cumulative effect of development on infrastructure should be taken into account. Sites include those which have been recently granted permission such as the Wokingham developments and Cabbage Hill, that are in the process of being built, or have not yet been started. The Borough Council has a great opportunity of looking strategically at areas where development is taking place and making provision to mitigate against the impact of that development across the area rather than merely making local changes for a specific development. Believes that the cumulative effect of the developments is not sustainable and additional development will put huge pressures on services such as water supply, doctor’s surgery (which is inadequate for the population it serves) road network and communications networks etc.

Environment Agency (ID1259) Policy LP3 includes 2 sites at flood risk – Cluster 5 & Cluster 7. Sites should only be allocated following application of the sequential test and where necessary the Exception test.

Cluster 5 falls partially within the functional floodplain (3b) and

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therefore should not be supported for housing without robust justification. Do not agree with the SA findings, that Policy LP3 meets Objective SA1 to avoid the risk of flooding.

There is no evidence in the draft sequential test demonstrating how the test has been applied and the reasoning for allocating these 2 sites, which are at flood risk. To ensure a sound Development Plan, it must be demonstrated how and why these have been allocated in preference to sites at lower flood risk.

Question why some sites in Flood Zone 1 have failed the sequential test as it does not apply to sites in Flood Zone 1.

Refer to national guidance on the application of the sequential test.

The results of the Level 2 SFRA currently being prepared should inform plan allocations and policies. EA are happy to provide advice and comment on this throughout the process.

Warfield Parish Council (ID670) Concerns about the siting of schools and lack of evidence to support location of them.

Thames Water Utilities Limited (ID733)

Limited opportunity to consider cumulative impact of sites in Policy LP3 – sewerage and water supply infrastructure comments have been assessed on an individual basis (see site entries). Therefore, impact of multiple sites in an area may have a greater impact. The scale, location and time to deliver required upgrades will be determined after receiving more certainty on location, type and scale of development and phasing.

TWUL welcomes working with BFC and developers/promoters, to identify the net increase in wastewater/water supply demand on their infrastructure.

Sport England (ID1044) Oppose development resulting in the loss of playing field land or formal built sports facilities unless its loss is justified by a robust and up-to-date assessment of need. As such, should any policy seeking to allocate any existing playing field land or formal built sports facilities for redevelopment, would strongly urge the Council to discuss this directly with Sport England before the next stage of the Local Plan. Object to the allocation of any sports facilities for development within the plan. (NB: no specific sites referred to within comments).


Partially supported, comments made on specific sites (see below).


COUNTRSYIDE/GREEN BELT/GAP/LANDSCAPE

Barrett (ID322) Concerns regarding reduction in countryside. Chavey Down Residents Association (ID456)

In relation to sites in Winkfield, agrees with Winkfield Parish Council, the following should be taken into account:

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Halting of erosion of the Green Belt, and gap separating Bracknell for Ascot.


Commend the Council for not allocating land in the Green Belt. However, the need to meet a housing requirement has meant the Council seeking to provide land for housing outside of Bracknell and beyond brownfield areas.

CHARACTER & DESIGN

R Banks (ID548) Comments made in relation to Binfield, but no specific site referred to.

Not considering village tranquil and green character Campaign to Protect Rural England Berkshire Branch (ID1105)

Justification for avoiding land for housing in the south west of Bracknell, at Crowthorne and Bracknell is understood and supported. However, this has resulted in allocations focussed in the north-east of Bracknell (Winkfield and Warfield). Concerned that these would be out of character with existing settlements, conflict with rural setting, unsustainable, and difficult to support necessary infrastructure. (Reference made to comparisons in terms of increase in dwellings/populations since the 2011 census to 2034 in these areas, such as a 39% increase in Winkfield/Cranbourne ward, and 37% in Ascot ward).

HOUSING

Hurst (ID57) Apartments being built for the retired, but nothing similar for the younger generation.

Valli (ID148) Comments made in relation to Martins Heron, but no specific site referred to.

No benefit for children, not affordable. Murphy (ID625) Para’s 6.25 and 6.28 inconsistent with allocation of LP6 and LP7. Jennings (ID1174) Forest Road / Warfield Street provides a natural northern boundary

to the town; potential sites to the south should be given greater priority for development (e.g. WAR4/WAR5 infinitely more suitable than WAR9/WAR10).

HISTORIC ENVIRONMENT

Butcher (ID978) Overall, whilst comprehensive the Plan is a missed opportunity. Continuation of the current plan sacrificing lifestyles/enjoyment of residents in the northern parishes (Binfield, Winkfield and Warfield), with green space developments damaging existing communities and harming heritage assess. There are five Grade II* heritage assets in Binfield (12 in the borough as a whole).

The Objectives set out at the beginning of the Plan are not being delivered by the Plan, which proposes to harm heritage assets and their setting rather than preserving them. There are no proposals for residential amenities, only removal of existing outdoor spaces, large urban sprawl, no solution to current and impending traffic/infrastructure issues.

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Plan will be more houses ignoring the need for affordable and older persons accommodation.

Where is the new thinking, opportunities for brownfield sites, co-operation with neighbouring authorities, and re-examination of existing sites yet to be built upon, and the proposals for local amenities and supporting infrastructure?


Unacceptable to detract from the many historic buildings NATURAL ENVIRONMENT (biodiversity, designated sites, green infrastructure, Thames Basin Heaths Special Protection Area)

Knight (ID127) Housing being built without thought for the environment. Barrett (ID322) Concerns regarding reduction in wildlife. Chavey Down Residents Association (ID456)


Adverse impacts of further development on the Special Protection Area.


Green spaces which are beneficial to residents' wellbeing R Banks (ID548) Comments made in relation to Binfield, but no specific site referred

to.

Impact on wildlife (slow worms, bats, etc.). CLIMATE CHANGE/ENVIRONMENTAL SUSTAINABILITY (flooding, drainage, pollution, contamination)

Hurst (ID57) Comments made in relation to Sandhurst, but no specific site referred to.

How is air and noise pollution taken account of?

Young (ID70) Comments made in relation to Winkfield Row/Warfield, but no specific site referred to.

There will be increased pollution with additional traffic. Patton (ID147) Comments made in relation to Forest Road, but no specific site

referred to.

Flooding has always been an issue in the area with overflowing drains and ditches: new roads, drives, pathways and houses will increase this problem.

Barrett (ID322) Consideration should be given to flood risk. Chavey Down Residents In relation to sites in Winkfield, agrees with Winkfield Parish Council,

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Association (ID456) the following should be taken into account:

Supply of water is at a worrying level, will be exacerbated by new development.

TRANSPORT

Larks (ID8/9) Comments made in relation to Warfield, but no specific site referred to.

Plan does not take account of additional cars/impact upon local road network (no provision for local road network/major routes improvements).

Hurst (ID57) Comments made in relation to Sandhurst, but no specific site referred to.

Traffic has steadily increased on Yorktown Road and Forester’s Way, which proposed developments will exacerbate (as most of commuting traffic is from M3, M4 or A30)

Hoare (ID59) Congestion (& pollution) already a problem, local planned developments will add to problems before any of the Local Plan developments occur – will the Plan include proposals to provide a road network capable of handling increased traffic without adding to congestion?

Young (ID70) Comments made in relation to Winkfield Row/Warfield, but no specific site referred to.

Traffic already congested. Many roads in the area are single carriage way, no room for expansion, and will not be able to cope with additional traffic.

Green (ID100) Roads not being modified to cope with traffic. Hitchcock (ID141) Comments made in relation to Binfield, but no specific site referred

to.

Roads will not be able to cope. Need better bus services. Patton (ID147) Comments made in relation to Forest Road, but no specific site

referred to.

Traffic builds up at the east end of Forest Road in the morning commute; more houses will add further congestion, another road will not improve congestion.


Already existing traffic and congestion. Chavey Down Residents Association (ID456)


Current highway infrastructure is struggling to cope with existing traffic at peak periods during the day, additional traffic will

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exacerbate the situation.. R Banks (ID548) Comments made in relation to Binfield, but no specific site referred

to.

Roads are very congested and the increase in traffic will make travel intolerable. This will destroy the pleasure of living in Binfield.


Focusing new housing to the east of Bracknell in a rural area is not sustainable (LP6 and LP7 referred to), as the sites are not close to main roads and transport nodes – bus railway, will mean high levels of car use by new residents). Lack of good bus services will lead to use of private vehicles to commute to employment areas/places of education in Bracknell/further afield. Locations are also likely to attract people to commute to places outside of the local area. Town planning principles which guided the new town development remain relevant (such as ensuring that facilities, infrastructure and connectivity are well provided for).

INFRASTRUCTURE

Hoare (ID59) The existing demand for GP and hospitals exceeds current supply, will the Plan include expanded provision of these services?

Hoare (ID59) Does the Plan include expanded provision of education services? Young (ID71) Local Dr surgeries already struggling, additional housing will add

future pressure, how ill this issue be addressed? Bunker (ID11), Williams (ID127), S Runham (ID495)

Local infrastructure will not cope (roads, doctors, schools, police, parking, services – water, gas, electricity).

Hitchcock (ID141), S Runham (ID495)

Comments made in relation to Binfield, but no specific site referred to.

Infrastructure (including GP surgeries, hospitals) will not be able to cope, area is already over populated. No hospitals.

Patton (ID147) Comments made in relation to Forest Road, but no specific site referred to.

Local supermarkets are already very busy and surely another supermarket is not in any future plans to further ruin the countryside.


Infrastructure (including GP surgeries/local hospital) will not be able to cope,

Chavey Down Residents Association (ID456)


Lack of secondary school provision in North Bracknell – many children in the areas are not able to attend a school of their choice, contrary to Government guidelines. Existing health services are under strain, without additional provision, further development is unsustainable. Local drainage and sewage systems cannot cope with additional development, existing system is inadequate.

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OTHER MATTERS

Williams (ID127) If the Council wants to attract younger people this is not the right development, they need to be near Reading Station.

Murphy (ID625) Considers it premature to indicate developable area boundaries in absence of completed evidence base (Para. 6.28).


CPRE Berkshire have objected to the Royal Borough of Windsor and Maidenhead Plan, due to the impact of proposed housing in the south west of that Borough, which is immediately adjacent to the Bracknell Forest wards (where development is proposed in Bracknell Forest Council). The local government boundary to the east of Bracknell between the two Boroughs is historic, but indistinct/not marked by any notable physical feature. Impact of the scale of new dwellings either side of the boundary has not been satisfactory examined by either authority.


Determining sewerage demands on proposed new development site by site is unacceptable, as it does not take into account cumulative effects of other developments or future developments.


Hunter Page Planning for Comments made of behalf of a specialist company working Castleoak (ID52/53) exclusively within the care sector.

Westwood House site is considered to be suitable and available for assisted living units, which would complement residential development being undertaken to the west and south of the proposed allocation. Castleoak are currently in discussion with DM officers regarding a development of c. 76 assisted living units on the site (use class C2).

Wellington College (ID721) Support the proposed allocation of 'Land East of Wokingham Road and South of Dukes Ride (Derby Field)'

Deloitte Real Estate for Bracknell Regeneration Partnership (The Lexicon) (ID878)

The draft Plan encourages high density development within Bracknell Town Centre (para. 5.13). Fig. 9 identifies sites which have been allocated for mixed-use, office, retail, leisure and high density development on the edge of Bracknell Town Centre . It is estimated there is capacity for a further 600-700 residential units in the Town Centre. BRP support development of residential led, mixed-use development, however the scale of retail and leisure offer on these edge of settlement sites should not detract or draw trade from Bracknell Town Centre.


Para 6.22 suggest sites proposed have a capacity of 3,651 dwellings; following site analysis, this should be reduced to 2,885 (numbers summarised here; refer to each site for justification):

• Land at Hideout and Beaufort Park: reduce capacity from 570 to 400 dwellings

• Land S of London Road, E of Bog Lane, W of Swinley Road: subject to drainage, locate secondary school on the site, reducing housing numbers (these can be provided on

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alternative sites) • Land at Winkfield Row: supported • Land at Hayley Green: rate of housing delivery should take

account of delays caused by several ownerships The Crown Estate (ID1420) Supports the inclusion of Wink22 as a proposed allocation in Policy

LP3. Also supports having site specific policies for the four large sites - should help bring forward their delivery in a timely and sustainable manner.

Bewley (ID 1472) Question the capacity of various sites proposed for allocation. Explanation given in accompanying Housing Evidence Base Paper.

Para 6.22 suggests a capacity of 3,651 dwellings from the sites listed in Policy LP3 - this should be reduced to 2,930. Therefore, additional sites will need to be allocated and included at Table 1. Should include land at Brookfield Farm, Warfield.

Proposed Change

Amend the content of Table 1 and add the following entry within the list of allocated sites;

War 12 – Brookfield Farm, Bracknell Road, Warfield – 60 (21)

Also amend trajectory. Gladman (ID1033) Essential that the housing supply to be provided from commitments,

windfall sites and proposed allocations is able to support the council in demonstrating a five year supply of deliverable sites that can be maintained over the plan period. Any assumptions relating to delivery from allocated sites within the housing trajectory should be formulated on realistic start dates and delivery rates.

Boyer on behalf of Luff Luff supports the allocation of Bin5 and Bin6 Developments (ID1328)

Draft Policy LP3 provides a suggested dwelling capacity for Bin5 of 40 dwellings and for Bin6 of 34 dwellings and welcomes that the figures are a “suggested dwelling capacity” and are not maximum and that there is flexibility with regards to the dwelling capacity

Luff welcome the clarification provided within draft Paragraph 6.23. The suggested dwelling capacities will need to be tested having regard to site constraints and through more detailed work such as masterplanning. In accordance with the NPPF, the Local Plan should seek to make the best and most efficient use of land and therefore allocations should not include a maximum figure.

Initial masterplanning work has been undertaken for Bin5 and Bin6 (see Appendix 6 of submitted report). This confirms that the suggested dwelling capacities set out within draft Policy LP3 are

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achievable. There could be scope to increase the number of dwellings within Bin5 and Bin6, depending upon design, density, existing trees, ecology and viability. More detailed work is currently being undertaken to assess in more detail the optimum capacity for these sites.

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Responses to Section: 6.2. Residential/mixed use development/Policy LP3. Site BIN1 – Land north of Tilehurst Lane

Site BIN1 – Land north of Tilehurst Lane




Binfield Parish Council (ID254) Site is close to listed buildings and will have a detrimental impact on their setting and significance. According to Historic England Binfield has at least 73 heritage assets including four grade II* listed buildings. Their preservation for future generations is important to the Parish Council.

Binfield Parish Council (ID254) Proposed access is from narrow lanes not built to accommodate the volumes of traffic proposed.


Wastewater treatment works is operating close to capacity. Recommend developer liaises with TWUL at earliest opportunity (according with NPPG) to determine magnitude of spare capacity and suitable connection point. On current information do not envisage concerns regarding wastewater infrastructure capability in relation to site.



Fish (ID448), Chilvers (ID660), Chilvers (ID727)

Concerns over erosion of countryside buffer; countryside defines the edge of the village.

Ketley (ID487), Batt-Rawden (ID1313)

Would detract from character and appearance of countryside.

Horan (ID1310) Example of insidious use of Green Belt for developers profit only.

CHARACTER

Wharpshire (ID307), Page (ID451), S Runham (ID495), Fitch (ID520), Sargent (ID531), Palmer-Hole (ID615), Chilvers (ID660), Chilvers (ID727), Campbell (ID735), Colby (ID739), Mitchell (ID851), Comper (ID977), Colebeck (ID1302)

Development of site would adversely affect character and appearance of land, and have negative / detrimental effect on character of area / village history (especially northern side of the village). Site is historic and tranquil. Should be preserved for future generations and quality of life for existing residents.

Wharpshire (ID307) Proposed density too high. Wharpshire (ID307) Proposed number of 40 houses is too high. Wharpshire (ID307), Ketley (ID487), Butcher (ID982)

Destruction of hedgerows would change the character of the area.

Fish (ID448), Chilvers (ID727) Development on edge of village will lead to loss of countryside charm and village aspect.

Chilvers (ID727) Poor lighting and narrow lane adds to charm and character of the edge of the village.

Leary (ID1220) Cites Character Area Assessment SPD “redevelopment along Tilehurst Lane should respect the rural character and setting of Binfield Park and retain the existing hedgerow”

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Wharpshire (ID307), Page Concerns about the detrimental effect development could have on (ID451), Wilson (ID460), Ketley many historic and listed buildings in the area (especially Grade II / (ID487), S Runham (ID495), Grade II* listed Binfield Park). Binfield Park is a ‘large country house Dainton (ID503), Fitch (ID520), set in parkland’ (according to Historic England). Setting of Binfield Sargent (ID531), Palmer-Hole Park will be affected by extensive building along Tilehurst Lane; (ID615), Chilvers (ID727), could harm setting of building, character of area and other heritage Campbell (ID735), Colby assets in area. Will destroy history of area. Must be protected for (ID739), Mitchell (ID851), residents and future generations (only 12 Grade II* buildings in Comper (ID977), Butcher Borough). (ID982), Leary (ID1220), Colebeck (ID1302), Batt-Rawden (ID1313), N Wilson (ID657) Ketley (ID487), S Runham Binfield Neighbourhood Plan Policy BF2 seeks to protect heritage (ID495), Butcher (ID982), Leary assets. Proposed development conflicts with this policy. Proposed (ID1220) development needs to consider the proximity to several listed assets

including Binfield Park (Grade II*), Gate Piers (Grade II), South Lodge to Binfield Park (Grade II), Honeysuckle Cottage (Grade II), Tile House (Grade II), Binfield Park Parkland and Park Lodge. Considered likely to overlook these neighbouring heritage assets. Impact on the background setting of these buildings.

Ketley (ID487), Butcher (ID982) Binfield Landscape Character and Heritage Assessment refers to following valued assets: Binfield Park Parkland, (Late 18th Century), Park Lodge (Mid to late 19th Century). BIN1 is in proximity to these assets. Considered to collectively contribute to setting and scene in this part of Binfield, anything which erodes their setting is detrimental to their significance.

Ketley (ID487), S Runham (ID495)

Site is higher than some of the Binfield Park setting, could create a sense of overlooking.

S Runham (ID495), Butcher (ID982)

Proposal contrary to draft BFLP Policy LP35.

Butcher (ID982) Hedgerows are important historic features. Butcher (ID982) Historic England stated it can see no justification for the harm the

development would cause the listed buildings contained on the site. Batt-Rawden (ID1313) Binfield Park House was tastefully redeveloped into residential some

years ago without impacting surrounding green space. NATURAL ENVIRONMENT (biodiversity, designated sites, green infrastructure, Thames Basin Heaths Special Protection Area) Wharpshire (ID307), Ketley Destruction of historic and native hedgerows would have an adverse (ID487), S Runham (ID495), effect on wildlife and biodiversity in the area. Some evidence of Chilvers (ID660), Butcher hedgerows already being removed along site boundary. (ID982) Fish (ID448), Dainton (ID503), Palmer-Hole (ID615), Chilvers (ID660)

Impact on wildlife in area, environment and conservation by eroding the countryside buffer. There is a wide variety of wildlife and nature. Irreplaceable habitats. References to deer, foxes, squirrels.

Ketley (ID487), Dainton (ID503), Hutchinson (ID535), Palmer-Hole (ID615), Colebeck

Further development would remove what little green space is left / wonderful green areas. Important for healthy walks in the countryside. Loss of green social areas.

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(ID1302) Ketley (ID487) Large number of trees with TPOs along Tilehurst Lane. S Runham (ID495), Dainton (ID503)

Would destroy biodiversity, trees, hedges and wildlife. Residents able to walk and breathe in what was a lovely village. No amount of mitigation could compensate for loss.

Hutchinson (ID535) Natural beauty of the area should be preserved. Horan (ID1310) Questions controls that will be in place to ensure planting of trees

and shrubs (deciduous mainly) by developers.

CLIMATE CHANGE/ENVIRONMENTAL SUSTAINABILITY (flooding, drainage, pollution, contamination)

Chilvers (ID660) Need to retain open green space for rain water to soak into the land. Seen impact of surface water flooding at the bridge at Wyevale and Three legged Cross junction in recent years. Effects of run-off will be compounded with further developments, surface water unable to soak in and be absorbed.

TRANSPORT Wharpshire (ID307), Fish Tilehurst Lane not suitable to take / unable to sustain increase in (ID448), Wilson (ID460), Ketley traffic. Was not designed to take endless streams of traffic. Traffic (ID487), S Runham (ID495), already diverts to avoid Binfield crossroads. Concerned about effect Palmer-Hole (ID615), Chilvers of increased traffic on country lane. Considered to be dangerous (ID727), Campbell (ID735), thoroughfare already. Additional homes would add to an already Colby (ID739), Lee (ID763), significant overload. Mitchell (ID851), Comper (ID977), Colebeck (ID1302), Horan (ID1310), Batt-Rawden (ID1313) Wharpshire (ID307), Page Country road is too narrow for vehicles to pass safely (road single (ID451), Wilson (ID460), Ketley lane at points), already very busy and dangerous with blind bend at (ID487), S Runham (ID495), bottom of hill. Road has poor sight lines. Would cause chaos at Dainton (ID503), Hutchinson rush hour. Has two bottlenecks. Concerns over existing visibility (ID535), Chilvers (ID727), Colby along road. (ID739), Lee (ID763), Comper (ID977), Colebeck (ID1302), N Wilson (ID657), Wharpshire (ID307), Ketley Increased traffic flow would be dangerous for users, including: (ID487), S Runham (ID495), residents, horse riders, pedestrians, children, mobility scooters, dog Chilvers (ID727), Comper walkers and cyclists (Tilehurst Lane is a designated bridle path). (ID977), Batt-Rawden (ID1313) Well used by local horse riders, runners, walkers, children, mobility

scooters and cyclists. Ketley (ID487), S Runham Development could adversely affect road safety, including for (ID495), Chilvers (ID660), children at Children’s nursery, and children walking to and from Chilvers (ID727), Comper school. (ID977) Page (ID451), Ketley (ID487), S Proposed access point onto Tilehurst Lane is at the narrow part of Runham (ID495), Fitch (ID520), the lane. Access from Tilehurst lane wholly unsuitable, especially in Sargent (ID531), Palmer-Hole combination with approved permission 15/00452/OUT. Entrance at (ID615), Campbell (ID735), top of hill would be extremely dangerous and would cause problems

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Colby (ID739), Lee (ID763), Mitchell (ID851), Comper (ID977), Colebeck (ID1302)

with traffic. Entrance would be immediately opposite pound place – would create T-junction and create unnecessary hazard.

Wilson (ID460), Ketley (ID487), S Runham (ID495), Dainton (ID503), Hutchinson (ID535), Chilvers (ID660), Chilvers (ID727), Lee (ID763), Comper (ID977), Colebeck (ID1302), N Wilson (ID567)

Cumulative impact of development in Binfield not sustainable (has consideration been given to including existing permissions not yet built out?). Village cannot support impact from traffic; pressure on roads / junctions already too great / (led to rat runs). Infrastructure of local road already clogged / reaching saturation point, especially during morning and evening rush hours, school drop off / pick up. References to increased pressure on existing junctions: Church Lane / Forest Road, roundabout on Terrace Road North, cross roads in village, cross village traffic, on small roads in and around Binfield. Church Lane junction dangerous / heavy flow down Church Lane without additional traffic. Will lead to congestion.

Wilson (ID460), Palmer-Hole (ID615), Chilvers (ID727), Campbell (ID735), Colby (ID739), Lee (ID763), Colebeck (ID1302)

Existing parking issues. Parking problems on Tilehurst Lane, Terrace Road North close to proposed development is virtually impassable due to parking on both sides of the road. Proposed development will exacerbate critical condition.

Ketley (ID487) Evidence of unsafe speeds recorded along Tilehurst Lane. Ketley (ID487), S Runham (ID495), Chilvers (ID727), Colby (ID739), Lee (ID763), Mitchell (ID851)

Tilehurst Lane does not have pavements, street lighting. Poorly lit.

Ketley (ID487) Site would have to be accessed off Tilehurst Lane adversely affecting flow of traffic. Contrary to CS Policy CS23.

S Runham (ID495), Chilvers (ID727), Horan (ID1310)

Construction traffic / delivery vehicles would drive up and down land close to where children play (Children’s nursery at top of lane). Builders will park up and down nearby road blocking drives and causing problems for existing residents. Will result in issues of mud, litter, foul language and parking. Site manager has no jurisdiction on where they park or how behave once left construction site. Consider providing an entrance from Forest Road for large vehicles.

S Runham (ID495) Existing paths and road have been destroyed by large lorries driving on the pavements everyday, leaving mud, dirt on paths and litter whilst existing developments are built out. Not suitable to have this near Children’s nursery.

S Runham (ID495) Pitts Bridge at other end of Tilehurst Lane will eventually erode and be destroyed if more traffic is allowed in this area.

Hutchinson (ID535), 45 homes could mean an additional 90 cars travelling down Tilehurst Lane in and out of Bracknell.

Lee (ID763) Tilehurst Lane will be natural short cut for traffic from this area of Binfield to the north end of the school site, when new school at Blue Mountain opens.

Horan (ID1310) Continued development down Tilehurst Lane will result in the lane needing widening to a dual carriage way to avoid traffic jams at peak school times.

INFRASTRUCTURE

Fish (ID448) Pressure on local services.

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S Runham (ID495) Doctors and hospitals cannot cope with extra demand from all new people moving into this area.

S Runham (ID495) Services e.g. water, gas, electricity will suffer with increasing demand.

Sargent (ID531), N Wilson (ID567)

Local infrastructure/public services (medical and education) will be unable to support new homes without reducing quality of life of existing residents.

Lee (ID763) Infrastructure in this area already overloaded: public services, water supply, drainage, and pollution control.

OTHER MATTERS

Wharpshire (ID307), Ketley (ID487)

Binfield Neighbourhood Plan must be taken into account.

Wharpshire (ID307), Ketley (ID487), Chilvers (ID660), Chilvers (ID727)

Proposed development is outside the defined settlement boundary. BFBLP ‘saved’ policies EN8 and H5 resist development outside of settlements. Settlement boundary amendments already considered through SALP to include Amen Corner sites and Blue Mountain. Expanding beyond Tilehurst Lane not appropriate.

Fish (ID448) Concerns development of site sets a precedent for further building on edge of villages.

Fish (ID448) Questions the increase in proposed number of dwellings from 40 to 45 (compared to original planning application).

Fish (ID448) Questions feasibility of building so many homes off Tilehurst Lane especially when only a small proportion are affordable housing.

Fish (ID448) Only a small proportion of the homes proposed are affordable (ideally prioritised for local people?).

Ketley (ID487), S Runham (ID495), Comper (ID977), Butcher (ID982)

Title record BK97612 stipulates an agreed build ratio of no more than 2 houses per acre on a significant part of the site.

Ketley (ID487), Colebeck (ID1302)

No account been made of collective sustainability of existing approved planning permissions on Binfield sites, such as Blue Mountain, Tilehurst lane, Amen Corner etc.

Ketley (ID487), Leary (ID1220) Proposed development considered contrary to CS1, CS7, CS23, EN20, Character Areas Assessment SPD and NPPF.

Redding (ID500) Objects to development of 45 houses. No reasons specified. Dainton (ID503), Sargent (ID531), Hutchinson (ID535), Palmer-Hole (ID615), Batt-Rawden (ID1313)

Already have too much building / many approved large developments; do not want further building plans passed in the village. How long will ‘Forest’ be able to be kept in name Bracknell Forest. Should be refused on basis that Binfield is already fulfilling its new homes obligation to the existing Local Plan.

Chilvers (ID660) Believe land is designated for forestry and agricultural use only. There must be a planning policy in place to protect it.

Chilvers (ID660) Growth in Binfield is not proportional to the rest of the borough. Lee (ID763) Combination of BIN1, BIN5 and BIN6 only adds a relatively small

number of homes at a considerable cost. Leary (ID1220) BFC were against and fought to the end the development at the

bottom of Tilehurst Lane. Considers reasons still apply to the rural character of Tilehurst Lane which should be protected.

Leary (ID1220), Batt-Rawden Objects to inclusion of site as an allocation.

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(ID1313) Colebeck (ID1302) Already lots of development in Binfield, of which, <15% have been

sold (ref: Bellway Site at Amen Corner). Do not require additional housing in Binfield – not selling. Loss of green spaces being replaced with eyesores and congestion.

Horan (ID1310) Work hasn’t started yet on the development at the south end of Tilehurst Lane.


Woolf Bond Planning on behalf Strongly supportive of allocation; under control of developer and can of JPP Land and Neal (ID896) deliver a medium density housing scheme early on in plan period

(within 5 years), and will help deliver much needed homes within Bracknell Forest. Agree with views that southern part of site acceptable for residential development. Allocation should go through to future stages of the Local Plan as an allocation for 45 dwellings in draft policy LP3. Considers that allocation advocates residential development north of Tilehurst Lane (established through appeal on application 16/01196/OUT).

Woolf Bond Planning on behalf Outline application been submitted for 40 dwellings (17/01174/OUT), of JPP Land and Neal (ID896) supported by built heritage statement. Considers acceptability of

pending scheme reflected in conclusions of it being a proposed allocation. Consider need for new homes outweigh any less than substantial harm to heritage asset. Considers proposed scheme includes appropriate measures to safeguard setting of nearby listed buildings. Refers to appeal on application 16/01196/OUT (para. 66 to 70). Refers to matters relating to current pending application 17/01174/OUT, but considers the proposed allocation should be taken into consideration. Representation accompanied by the Built Heritage Statement.

Woolf Bond Planning on behalf of JPP Land and Neal (ID896)

Refers to Appeal at Newhurst Gardens (APP/R0355/W/17/3182713). Refers to outcomes of several appeals within the borough and challenges faced by authority. Quotes para. 35 of appeal.


An outline planning application for 40 dwellings has been submitted to the Council for this site (Application Ref: 17/01174/OUT), but concerns have been raised by the Council’s Urban Design Officer., and reference also made to a scheme on neighbouring land at Tilehurst Lane (with a subsequent appeal allows APP/R0335/W/15/3139035).

Note that the Housing Background Paper states (page 65 & 66) that this is a semi- rural site on the edge of a settlement and would represent a ‘rounding off’ of the settlement. Disagree with this conclusion as the existing vegetation on the southern boundary of the site provides a strong boundary to the settlement and a development of land between the existing settlement boundary and Binfield Park would exhibit a more rural character.

On the basis of the above, consider that a lower density development would be more appropriate in this location therefore the

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capacity of the site should be reduced by at least 20 dwellings to a capacity of 25 dwellings.

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Responses to Section: 6.2. Residential/mixed use development/Policy LP3. Site BIN5 – Land south of Forest Road and east of Cheney Close

Responses to Section: 6.2. Residential/mixed use development

Site BIN5 – Land south of Forest Road and east of Cheney Close




Binfield Parish Council (ID254) The loss of open space will damage the community of Binfield far more than the small net gain in housing.

Binfield Parish Council (ID254) The site is an open space of considerable value to the community, contributing to the rural feel of Binfield village. The Binfield Parish Landscape Character Assessment – PLCA 6: Binfield Major Green Infrastructure states that: “In addition to the list of heritage assets, this includes the historic group value of Wood Lane, of Forest Road, their boundary treatment, woodland and mature tree cover, hedgerows, ditches and ponds. It is equally important to conserve and enhance the character of the rural approaches to Binfield and the well-defined natural boundaries that interface with the adjacent character areas.” Development will materially affect the rural approach to Binfield from Cabbage Hill and will remove a link between the centre of the village and its rural and agricultural past.

Binfield Parish Council (ID254) Site has long-established hedgerows and protected trees and is rich in wildlife.

Binfield Parish Council (ID254) Strongly opposes development on the site (reasons listed under the appropriate sub-headings).

Binfield Parish Council (ID254) Residents are strongly opposed to development. When the development of Blue Mountain was proposed, residents were promised that the site would form part of the open space surrounding Blue Mountain. Residents and feel strongly that the Borough Council should keep that promise.

Binfield Parish Council (ID254) Development will exit onto Forest Road, which has become increasingly busy from developments in Wokingham. It is also next to the proposed drop-off area for the new secondary school on Blue Mountain. There will be an increase in traffic from dropping students off and from parents waiting in parked cars, leading to increased congestion. Additional traffic from any development will add further congestion to Forest Road.

Binfield Parish Council (ID254) The site is a recognised beauty spot and the view from the top is irreplaceable. It should not be removed.


On current information do not envisage concerns regarding wastewater infrastructure capability in relation to site.



Evans (ID159), Smith (ID161), Davis/Skaife (ID225), Elliott (ID228), Graham (ID230), Ketley (ID231), Fraser (ID232), Lunn (ID234), Weber (ID235), Harris

Building on the site will not maintain significant land / gap between development (Binfield and Bracknell). Previously led to believe / assured / promised by Council / conveyancers / searches that BIN5 and BIN6 would be maintained as green space / SANG to separate Binfield from Bracknell (Development Plan / Policy SA7 / Binfield

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(ID301), Watson (ID303), L . Page (ID304), N. Page (ID306), A. Page (ID310), Underhill (ID457), Harvey (ID458), E. Harvey (ID472), Andrews (ID473), R. Glover (ID475), P. Glover (ID478), Preston (ID481), J and C Sinclair (ID489), Bryant (ID490), N and F Moynihan (ID494), R Kentish (ID496), S Runham (ID495), Shirley (ID497), Whelan (ID499), Hutton (ID504), V Baker (ID 514), K Dagnall (ID515), Leakey (ID519), N Glover (ID521), R Davies (ID522), Heyes (ID524), G Baker (ID525), T Baker (ID527), W Low (ID528), K Ross (ID532), Stilgoe and Holdford (ID533), J Unwin (ID534), A and S Cocking (ID536), R Warren (ID540), R Baloch (ID542), A Glover (ID550), A McFaul (ID551), A Baylis (ID553), K Baylis (ID568), K Wilson (ID590), K Aherne (ID592), P Maddox (ID604), S Kelley (ID609), A and C Whitney (ID610), R Willmott (ID618), T User (ID629), T Chizlett (ID645), S Clark (ID655), N Wilson (ID657), S and E Whatley (ID732), Sibley (ID734), A and R Lambourn (ID744), P Harvey (ID747), P Kendall-Savegar (ID748), C and L Jacobs (ID757), M Goodwin (ID760), P Chizlett (ID810), L Harris (ID859), G Ramsey (ID866), G Boorman (ID869), C Boorman (ID872), C and S Palmer (ID934), M Long (ID935), Chalmers and Taylor-Cutter (ID940), E and B Glasson (ID974), J Clark (ID976), S Butcher (ID982), J Blamire (ID994), R Baloch (ID745), D Chidwick (ID1039), G Gibson (ID1048), J Harvey (ID1099), G Buffet (ID1100), J Sones (ID1248), Z Baloch (ID1309), J


Neighbourhood Plan / Section 52 Planning Agreement for Blue Mountain) when Blue Mountain was developed and Council has gone back on its promise.

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Norfolk (ID1339), P Fennel (ID1341), A Reynolds (ID1342), J Maloney (ID1358) Reeves (ID104), Marriott Sites (BIN5 and BIN6) separate Bracknell / Temple Park / Blue (ID156), H, F and S Farthing Mountain from Binfield. Building on them will not maintain significant (ID612), N Hanson (ID656), C gap / Green Belt will and merge Bracknell and Binfield, losing the and A Rivera-Valez (ID491), S village identity. Byron (ID736), A and R Lambourn (ID744), A and E D’Aubyn (ID995), J Harvey (ID1099), J Wilmott (ID1309), J Norfolk (ID1339), D Kiernan (ID1340), P Fennel (ID1341) P Maddox (ID604) Sites (BIN5 and BIN6) form part of the gap between Binfield and

Bracknell - Section 5.25 “to prevent neighbouring towns merging into one another” and Section 11.2 / Policy LP12 ‘Landscape character and strategic gaps’.

S Clark (ID655) Sites (BIN5 and BIN6) form part of the Local Gap between Bracknell and Binfield. This Local Gap was identified in the Inspector’s report in 2007 and the Adopted Core Strategy of 2008 and the Inspector’s Report of 2013. The Blue Mountain Golf Course helped to maintain this recognized Local Gap, but as a result of Policy SA7 this Local Gap has been severely degraded. Development of sites Bin5 and Bin6 would further degrade this Local Gap in direct contravention of Policy SA7, Inspector’s Reports of 2007 and 2013 and Bracknell Forest Council’s Adopted Core Strategy - February 2008. (extracts from Site Allocations Local Plan 2013, Bracknell Forest Council Site Allocations Local Plan, Inspectors Report June 2013, Bracknell Forest Borough Council LDF – Core Strategy DPD Examination – Inspector’s Report 2007, Core Strategy 2008

S Clark (ID655) In contravention of Inspectors Report of 2007 (Core Strategy examination) 2008 and 2013 (Site Allocations Local Plan) which clearly suggest that the development of the land should be to the South of the Blue Mountain site and not to the North where sites Bin5 and Bin6 are located. (extracts from above reports)

S Clark (ID655) The defined settlement boundary for Binfield does not include Sites Bin5 and Bin6. Moving the boundary to include these sites further degrades the defined local gap and visual separation between Binfield and Bracknell as identified in Inspector’s Report of 2013. It would also be in direct contravention to Bracknell Forest Council’s Core Strategy 9. (extracts from Core Strategy 2008 and Site Allocations Local Plan Inspectors Report 2013)

J Sones (ID1248) The gap is a site of historic and natural interest C and L Jacobs (ID757) The Binfield Landscape Character Assessment recommends that the

gap be maintained in order to conserve the open and rural character of Binfield.

S Carter (ID1222), D Carter Developing the sites (BIN5 and BIN6) will remove the strategic green (ID1223) gap between Bracknell and Binfield. The Local Plan states that

developments should “enhance the natural and historic environment, including landscape.” How is this the case if you develop these

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sites? A and M D’Aubyn (ID995) The argument that these sites (BIN5 and BIN6) just fill in boundary

gaps only shows the misunderstanding of the nature of an English village and what it means to the inhabitants. Symmetry and neatness are planning terms, not residents

Evans (ID159), Smith (ID161), Contrary to Policy CS2 and NPPF as brownfield should be utilised / Lunn (ID234), Weber (ID235), prioritised over green field sites. Brownfield sites have come forward Davis/Skaife (ID225), Harris which have not been included. Many available in Bracknell / the (ID301), Harvey (ID458), E. Borough including empty offices / commercial buildings. Harvey (ID472), R. Glover (ID475), P. Glover (ID478), Preston (ID481), J and C Sinclair (ID489), Bryant (ID490), M Kentish (ID493), R Kentish (ID496), Shirley (ID497), Whelan (ID499)), N Glover (ID521), R Davies (ID522), Heyes (ID524), G Baker (ID525), T Baker (ID527), W Low (ID528), Stilgoe and Holdford (ID533), J Unwin (ID534), R Warren (ID540), A McFaul (ID551), A Baylis (ID553), K Baylis (ID568), K Aherne (ID592), P Maddox (ID604), A and C Whitney (ID610), E Bradley (ID611), R Willmott (ID618), T Chizlett (ID645), A and R Lambourn (ID744), C and L Jacobs (ID757), M Goodwin (ID760), P Chizlett (ID810), K Williams (ID863), G Ramsey (ID866), G Boorman (ID869), C Boorman (ID872), Chalmers and Taylor-Cutter (ID940), E and B Glasson (ID974) E and B Glasson (ID974), J Clark (ID976), R Baloch (ID745), D Chidwick (ID1039), J Harvey (ID1099), S Carter (ID1222), D Carter (ID1223), Z Baloch (ID1309), D Kiernan (ID1340), J Maloney (ID1358) V Baker (ID514) NPPF states that Brownfield sites should be considered and the draft

NPPF states that local planning authorities should take a proactive role in identifying and helping bring forward land for development. Why isn't the Council looking at this rather than small sites (BIN5 and BIN6) where you can fit a small percentage of houses in comparison to the need?

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J Clark (ID976) Council should be more pro-active about thinking about future brownfield sites that may come forward and develop green space like BIN5 and BIN6 when another large development opportunity may be around the corner. The next version of the NPPF will require Councils to be more pro-active in searching for brownfield sites.

K Dagnall (ID515), H, F and S Should focus / develop brownfield sites. Farthing (ID612), T Bradley (ID619), N Hanson (ID656), P Kendall-Savegar (ID748), J Sones (ID1248) A and E D’Aubyn (ID995), Questions why greenfield sites are being put forward before

brownfield – builders favour them J Blamire (ID994) Should develop brownfield before Green Belt. The government

attach importance to the Green Belt (extract from NPPF) Graham (ID230) Is this not a greenfield site (BIN5 and BIN6)? How much greenfield

can you take from one parish? Watson (ID303) What about the commitment to the Green Belt? B Wetherall (ID746) Green Belt in danger of disappearing CHARACTER

Reeves (ID98) Site not suitable for allocation, will destroy the village / loss of village amenity.

Evans (ID159), Smith (ID161), The sites (BIN5 and BIN6) forms part of the rural character / peace / Elliott (ID228), Ketley (ID231), tranquillity / sense of place / identity of the village. Just be an E. Bradley (ID312), Harvey extension of Bracknell. (ID458), E. Harvey (ID472), Andrews (ID473), P. Glover (ID478), Preston (ID481), M Kentish (ID493), R Kentish (ID496), S Runham (ID495), Shirley (ID497), Whelan (ID499), Hutton (ID504), V Baker (ID514), K Dagnall (ID515), A Kelly (ID523), Heyes (ID524), G Baker (ID525), T Baker (ID527), K Ross (ID532), J Unwin (ID534), A Cocking (ID536), A Glover (ID550), A McFaul (ID551), K Aherne (ID592), A and C Whitney (ID610), E Bradley (ID611), H, F and S Farthing (ID612), R Willmott (ID618), T Bradley (ID619), S Bradley (ID639), N Wilson (ID657), S and E Whatley (ID732), A and R Lambourn (ID744), C and L Jacobs (ID757), M Goodwin (ID760), C Reynolds (ID762), K Williams (ID863), G Ramsey

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(ID866), C and S Palmer (ID934), M Long (ID935), J Clark (ID976), S Butcher (ID982), J Harvey (ID1099), G Buffet (ID1100), D Kiernan (ID1340), P Fennel (ID1341)

B Runham (ID171), Green (ID229), Weber (ID235); Watson (ID303), Shirley (ID497), Whelan (ID499), Heyes (ID524), K Ross (ID532), A Baylis (ID553), K Baylis (ID568), N Hanson (ID656), S Byron (ID736), P Barton (ID741), G Ramsey (ID866), M Long (ID935), Z Baloch (ID1309), J Maloney (ID1358)

Overdevelopment of the area / loss of village identity. Too many recent developments (Murrell Hill Lane, Terrace Road South, Forest Road, and larger development close to Coppid Beech, 3 legged Cross and Blue Mountain).

L. Page (ID304), N. Page (ID306), A. Page (ID310)

Village should be protected not destroyed by over development of green space.

Fern (ID226) Loss of green space would lead to the irreversible loss of character and value to the community on a mental health and well being level. Avoiding over development and incorporating planting of trees etc. would go some way to mitigate this. Important to get the aesthetics right.

B Runham (ID171) Consideration should not be given to this site in isolation, but impact upon the character, taking account of other development in Binfield.

P. Glover (ID478) To have houses all along the Forest Road would undermine the village feel of Binfield.

A and R Lambourn (ID744) Residents adjoining plots will be overlooked reducing peace and privacy.

Bradley (ID480) Will make Binfield ugly Smith (ID161) Site is adjacent historic Wood Lane.

E and B Glasson (ID974) Past development has eradicated many very old and familiar buildings and substantially detracted from the essential character of the village. The southern part of the Parish, unrecognisable.

HOUSING Reeves (ID98); Ketley (ID231), Lunn (ID234); Harris (ID301), Underhill (ID457), R. Glover (ID475), P. Glover (ID478), R Kentish (ID496), R Davies (ID522), Heyes (ID524), W Low (ID528), K Ross (ID532), J Unwin (ID534), R Warren (ID540), K Wilson (ID590), K Aherne (ID592), P Maddox

Small gain in housing numbers compared to impact.

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(ID604), A and C Whitney (ID610), T Chizlett (ID645), N Wilson (ID657), S and E Whatley (ID732), P Kendall-Savegar (ID748), C and L Jacobs (ID757), P Chizlett (ID810), K Williams (ID863), M Long (ID935), J Clark (ID976), S Butcher (ID982), D Chidwick (ID1039). Davis/Skaife (ID225) Don’t believe it was intended to be government policy to bulldoze

through development. Sites (BIN5 and BIN6) will provide a small number of homes for millionaires with expensive social housing.

E. Bradley (ID312) Not opposed to building houses but the Council needs to find more suitable locations

V Baker (ID 514) No change in housing demand since assured that BIN5 and BIN6 were SANG. This is evidenced by the new properties on Terrace Road South which are still up for sale. Has the Council has considered the impact of Brexit on the plan for our area in particular as regards population and economic development?

R Warren (ID540) Current plans already exceed the requirements for new homes therefore there is no justification to include any extra development in Binfield.

K Baylis (ID568), Do we need to build houses for people who work elsewhere? Leakey (ID519) Should refuse permission until the properties that are being built now

have been completed and lived in for a while and review the situation at a later time.

A and R Lambourn (ID744), This further development is being proposed before the impact of new development is known. Better to pause development in this area of Binfield until the Council can properly assess the impact on infrastructure, society / village structure / fabric, and urban / rural landscape to incorporate wisdom and experience into future planning decisions. Without this could be construed as environmental vandalism.

G Ramsey (ID866) Believe have met/ exceeded, the Government’s quota for housing. If so any new housing developments are superfluous. The area is now in danger of becoming seriously over developed.

E and B Glasson (ID974) Local communities are being threatened by more development, the amount of land in the Draft Local Plan exceeds the amount of land needed according to the Council’s own housing need assessment.

G Gibson (ID1039) Number of other less intrusive sites which will not have such a detrimental effect on Binfield, its services or the residents.

J Harvey (ID1099), S Carter (ID1222), D Carter (ID1223)

Binfield taken heavy share / fair share of new housing over last few years


Lunn (ID234), Preston (ID481), R Kentish (ID496), R Davies

Important to the character and setting of Binfield village which has over 70 / 73 / 708 listed structures/heritage assets

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(ID522), R Warren (ID540), K Aherne (ID592), P Maddox (ID604), T Chizlett (ID645), C and L Jacobs (ID757), P Chizlett (ID810), J Clark (ID976), D Chidwick (ID1039), D Kiernan (ID1340), E. Bradley (ID312), E Bradley (ID611),

Fields part of the historic environment/name of village

Hutton (ID504) Over development out of character in a village of multiple listed buildings

P Maddox (ID604) Contrary to Policy LP1 (iv) to “protect and enhance the natural environment and heritage assets together with their settings”. (comment also under historic environment)

C and L Jacobs (ID757) Sites (BIN5 and BIN6) are areas of high archaeological potential, which should also be respected and preserved.

NATURAL ENVIRONMENT (biodiversity, designated sites, green infrastructure, Thames Basin Heaths Special Protection Area)

Reeves (ID98), Evans (ID159), Existing trees / TPOs, established / protected / ancient hedgerows / Ketley (ID231), Lunn (ID234); woodland and ancient meadows. Harris (ID301), R. Glover (ID475), Preston (ID481), Bryant (ID490), M Kentish (ID493), N and F Moynihan (ID494), R Kentish (ID496), S Runham (ID495), K Dagnall (ID515), N Glover (ID521), R Davies (ID522), W Low (ID528), J Unwin (ID534), A and S Cocking (ID536), R Warren (ID540), A McFaul (ID551), K Baylis (ID568), K Wilson (ID590), K Aherne (ID592), P Maddox (ID604), T Chizlett (ID645), S Clark (ID655), N Wilson (ID657), M Goodwin (ID760), P Chizlett (ID810), K Williams (ID863), G Boorman (ID869), C Boorman (ID872), Chalmers and Taylor-Cutter (ID940), J Clark (ID976), S Butcher (ID982), D Chidwick (ID1039), G Gibson (ID1048), S Carter (ID1222), D Carter (ID1223), Z Baloch (ID1309), D Kiernan (ID1340), J Maloney (ID1358) Coker (ID157), Andrews (ID473), C and L Jacobs (ID757), R Woolford (ID998),

Hedges within the site are used by bird species / support a large variety of bird (including Nuthatches, Goldfinches, Goldcrests, Long-tailed tits, Lesser Spotted Woodpeckers, Green Woodpeckers,

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Fieldfares, wrens, Sparrow hawks, other woodland birds) so should be preserved / retained.

Reeves (ID98), Evans (ID159), Impact on wildlife / habitats / plants (including hedgehogs, birds, Davis/Skaife (ID225), Ketley owls, bats (including pipistrelle bats), pheasants, deer, roe deer, (ID231), Lunn (ID234); Harris foxes, grass snakes, slow worms. field mice, butterflies, insects, (ID301); Watson (ID303), E. horses, ponies, newts, insects). Bradley (ID312), Andrews (ID473), R. Glover (ID475), Bradley (ID480), Preston (ID481), Bryant (ID490), M Kentish (ID493), N and F Moynihan (ID494), R Kentish (ID496), S Runham (ID495), K Dagnall (ID515), N Glover (ID521), R Davies (ID522), Heyes (ID524), W Low (ID528), J Unwin (ID534), A and S Cocking (ID536), R Warren (ID540), A McFaul (ID551), A Baylis (ID553), A Baylis (ID553), K Baylis (ID568), K Wilson (ID590), K Aherne (ID592), P Maddox (ID604), A and C Whitney (ID610), E Bradley (ID611), T Bradley (ID619), S Bradley (ID639), T Chizlett (ID645), N Hanson (ID656), N S Byron (ID736), Wilson (ID657), S and E Whatley (ID732), Sibley (ID734), P Kendall-Savegar (ID748), C and L Jacobs M Goodwin (ID760) (ID757), C Reynolds (ID762), P Chizlett (ID810), L Harris (ID859), K Williams (ID863), G Boorman (ID869), C Boorman (ID872), Chalmers and Taylor-Cutter (ID940), J Clark (ID976), S Butcher (ID982), D’Aubyn (ID995), D Chidwick (ID1039), G Gibson (ID1048), S Carter (ID1222), D Carter (ID1223), J Sones (ID1248), Z Baloch (ID1309), D Kiernan (ID1340), P Fennel (ID1341), J Maloney (ID1358) Chalmers and Taylor-Cutter (ID940)

Provision must be made in the area for species support and protection given the amount of development

C and L Jacobs (ID757) Policy LP18 – Design criteria iii states that all new developments must “retain and, where reasonable, enhance existing trees,

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important open areas, gaps in frontages, hedgerows, walls, fences, banks and other site features of landscape, ecological, heritage or amenity value.” Proposing to build on the sites (BIN5 and BIN6) will significantly reduce, ruin and negatively impact the wildlife, existing trees, hedgerows, walls, banks, grassland and little scrub land that Binfield has left.

Davis/Skaife (ID225), E and B Glasson (ID974), J Wilmott (ID1309)

Last remnants of a natural environment on east side of Binfield (BIN5 and BIN6).

Ketley (ID231), Fraser (ID232), Lunn (ID234); Harris (ID301), Underhill (ID457), R. Glover (ID475), R Kentish (ID496), Whelan (ID499), R Davies (ID522), W Low (ID528), K Ross (ID532), J Unwin (ID534), R Warren (ID540), K Wilson (ID590), K Aherne (ID592), P Maddox (ID604), H, F and S Farthing (ID612), T Chizlett (ID645), N Wilson (ID657), S and E Whatley (ID732), P Kendall-Savegar (ID748), C and L Jacobs (ID757), P Chizlett (ID810), G Boorman (ID869), C Boorman (ID872), M Long (ID935), J Clark (ID976), D Chidwick (ID1039), G Gibson (ID1048), J Harvey (ID1099), S and D Carter (ID1222-1223), Z Baloch (ID1309), D Kiernan (ID1340), E and B Glasson (ID974),

Loss of further open space damaging to community / environment which outweighs contribution to housing targets.

E Harvey (ID472), P Glover (ID478), F Drew (509), H, A and S Farthing (ID612), G Sibley (ID734), S Carter (ID1222), D Carter (ID1223), S Runham (ID495), J Norfolk (ID1339)

Feeding / looking at ponies / horses

P Barton (ID741) Promised to maintain open spaces. P Barton (ID741), P Harvey (ID747)

Concern that there will be no green spaces left

E. Bradley (ID312) Sites (BIN5 and BIN6) should be protected as ‘Local Green Space’. Andrews (ID473) Leave so sites continue to provide attractive natural green space, far

more valuable as a wildlife corridor than park-style spaces. S Runham (ID495) Important to retain as green space to offset urbanisation around area

(Cabbage Hill to Amen Corner North and South). Preston (ID481), C and L Jacobs (ID757)

Sites should be open space.

J Clark (ID976), Council should purchase the sites (BIN5 and BIN6) in order to make

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for public open space. J Norfolk (ID1339) Welcome that there will still be an area of land allocated for golf

course, allotments and an area of green space near the Binfield Manor house. However, the green space near the Manor is on the edge of the village and is flat and probably marshy, whereas the land allocated to BIN6 is easily accessible to large numbers of villagers and their children.

Elliott (ID228), P. Glover (ID478), Preston (ID481), S Runham (ID495), N Glover (ID521), A and C Whitney (ID610), H, F and S Farthing (ID612), R Willmott (ID618), P Harvey (ID747), J Clark (ID976)

Children/residents need to experience / spend time in / enjoy / view open green spaces to enhance the quality of their lives / mental health / well being.

C and A Rivera-Valez (ID491) Without green spaces feels claustrophobic and overpopulated and vehicle fumes become unbearable and psychological and physical health deteriorate.

J Blamire (ID994) Have taken away view of golf course Reeves (ID102) The site contains all aspects referred to in section 17.1.3, ignoring

this and building on the site is not sustainable or green. S Runham (ID495), S Butcher (ID982)

Contrary to Policy LP38 - Green Infrastructure as it would fragment green infrastructure and create barriers to the movement of people, biodiversity and water.


Fraser (ID232) Ancient sites (Bin5 and Bin6) where the old oaks from Windsor Forest are still features of the landscape.

Whelan (ID499) Understand that developments have to provide sufficient SANG space for the number of units that have been approved. Is this still the case given the amount of development taking place in and around Binfield?

S Clark (ID655) Changing the designation of the land from SANG so soon after the adoption of Policy SA7 and the land’s subsequent planning permission is in direct contravention of the Council’s own decision and the Planning Inspector’s reports of 2007 and 2013. (extracts from Site Allocations Local Plan and Document – SAL110 -Statement of Common Ground: Luff Developments Ltd).

S Clark (ID655) Site is under policy CS14: Thames Basin Heaths Special Protection Area. Site Allocation Local Plan Map 40 shows the land being dissected by the boundary of the Thames Basin Special Protection Area. Whilst this policy does not prevent the development of the land, it does call for sufficient SANG / Open Space to be provided to offset the development. As sites Bin5 and Bin6 have been assigned as SANG / Open Space question appropriateness for development. (extracts from Core Strategy 2008,Site Allocations Local Plan 2013 and SAL110 - Statement of Common Ground: Luff Developments Ltd).


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Hayes (ID12) Sewage system cannot cope with existing houses, existing sewage flooding, other properties could suffer.

B Wetherall (ID746) May be flooding if drains can’t cope. Reeves (ID98), Marriott (ID 156), S Jones (ID1248)

Flood risk/poor drainage.

R Woolford (ID998) Bungalows opposite the BIN5 site have had problems with flooding when the rainfall has been heavy. Development would make things worse

J Sones (ID1248) Existing drains already fail to cope e.g. Hillside Drive and can only deteriorate

S Runham (ID495), S Butcher (ID982)

High risk of surface water flooding on Environment Agency flood map

D and M D’Aubyn (ID995) Waterlogging in winter R. Ludlam (ID467) Garden gets very wet and could get worse when build. J Norfolk (ID1339) Site at risk of flooding and concerned that home is located between 2

identified flood risk zones (BIN5 and BIN6) and is at risk of flooding. A and R Lambourn (ID744) Problems with current developments in Binfield regarding adequate

drainage of land (e.g. Woodhurst Park green area which is boggy). Poor natural drainage, increased volume and speed of surface run-off and poor maintenance of drainage channels/ditches/gullies contribute to increased volume of surface run-off and quicker delivery into any drainage channels which are often unable to cope. These artificially raised amounts have to be factored in to any development plans. The impervious clay often means that surface water is puddled on the surface causing boggy land. These factors put huge short term strain on drainage systems and often leading to flash flooding (road outside Wyevale Garden Centre, east of the Stag and Hounds, is frequently flooded which is the area where more “concreting over” of the land is going to take place with the already approved pick-up and drop-off zone for the school.

A and R Lambourn (ID744) Pressure on effluent disposal from developing the site risks problems, particularly as the impact of the Blue Mountain development has yet to make itself felt (apparently inadequately sized effluent disposal pipes for the Woodhurst Park development are going to cause problems).

Chalmers and Taylor-Cutter (ID940)

Area around The Stag and Hounds and Wyevale Garden Centre area frequently floods. Additional paved and built up areas in BIN5 and Bin6 areas can only exacerbate this issue and the impact of Blue Mountain development impact on these areas is yet to be seen. Too much development and will ruin the area’s ability to handle the volume of water after heavy rainfall.

Higgins (ID174) Increased noise from traffic. Chalmers and Taylor-Cutter (ID940)

People who are moving to the area will be impacted by the noise pollution from the redirection of air traffic to / from Heathrow. Mobile phone service is interrupted and the sound is loud inside the house. Has this been considered?

Davis/Skaife (ID225), K Williams (ID863),

Japanese knotweed infestation (BIN5 and BIN6).

TRANSPORT

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Banks (ID19), (Marriott (ID156), Evans (ID159), Smith (ID161), B Runham (ID171), Rawsthorne (ID173), Higgins (ID174), Elliott (ID228), Ketley (ID231), Fraser (ID232), Weber (ID235); Harris (ID301), Brown (ID389), Prior (ID390), Ludlam (ID414), Underhill (ID457), R. Glover (ID475), P. Glover (ID478), J and C Sinclair (ID489), Bryant (ID490), M Kentish (ID493), R Kentish (ID496), S Runham (ID495), Shirley (ID497), Whelan (ID499), King (ID502), V Baker (ID514), K Dagnall (ID515), Leakey (ID519), A Kelly (ID523), Heyes (ID524), K Ross (ID532), Stilgoe and Holdford (ID533), A and S Cocking (ID536), R Warren (ID540), R Baloch (ID542), A Glover (ID550), A Baylis (ID553), K Baylis (ID568), K Wilson (ID590), G King (ID606), A and C Whitney (ID610), E Bradley (ID611), H, F and R Willmott (ID618), S Farthing (ID612), T Bradley (ID619), T Chizlett (ID645), N Hanson (ID656), S and E Whatley (ID732), Sibley (ID734), S Byron (ID736), P Barton (ID741), A and R Lambourn (ID744), B Wetherall (ID746), P Harvey (ID747), C and L Jacobs (ID757), M Goodwin (ID760), C Reynolds (ID762), P Chizlett (ID810), L Harris (ID859), G Boorman (ID869), C Boorman (ID872), C and L Prior( (ID931), C and S Palmer (ID934), Chalmers and Taylor-Cutter (ID940), E and B Glasson (ID974), J Clark (ID976), S Butcher (ID982), R Baloch (ID745), D’Aubyn (ID995), R Woolford (ID998), J Harvey (ID1099), J Norfolk (ID1339), P Fennel (ID1341), O Brown (ID1356), P Hadley (ID1357)


Increased traffic will be unsustainable / unacceptable and will increase congestion / increase pollution / reduce quality of life / be hazardous for children. Already adverse effects such as congestion / busy roads with cars parked on roads / roads in poor condition/damage to verges from other development in the area (Blue Mountain and associated school with 1800 pupils, Fox Lane area, Tilehurst Lane Area, Woodhurst Corner, Amen Corner, estates in Warfield, Wokingham). Roads referred to in comments: Terrace Road North South, Forest Road, Binfield Road, Cheney Close

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An integrated traffic plan for Binfield, Wokingham, Warfield and the areas immediate to these cannot be based on a set of data which reflects imminent reality. Roads in and around Binfield Village cannot have been assessed of being capable of handling the massive rise in traffic capacity that is due.

S Butcher (ID982) No coherent strategy to deal with traffic impacts of all developments M Long (ID935) Forest Road and infrastructure not designed for increased traffic P Fennel (ID1341) Section of village could become a rat run Z Baloch (ID1309) The mini-roundabout at the centre of the village cannot sustain the

increase in traffic from Binfield Learning Village let alone BIN5 and Bin6. The recent temporary traffic lights at the mini-roundabout for essential road repairs resulted in long tail backs on Forest Road which would be a daily occurrence with further development

Fern (ID226) Each new home is likely to have at least one car. The volume of traffic from both sites (BIN5 and BIN6) would increase. If all the new residents had to go through the village it would cause delays both at the bridge end of the village and at Saint Marks church end for all commuting .If they had access via the golf course road it would solve some of that.

J Sones (ID1248) The buildings and road expansion will overload the congested roads leading around and into the site, converting quiet cul-de-sacs into noisy vehicular thoroughfares.

B Wetherall (ID746) Possibility of properties being damaged by traffic R. Ludlam (ID467) Concern about access from the Forest Road. It is already very

dangerous as cars speed through the village. The bungalows opposite BIN5 park on the road and development will make it worse.

Burrowes and Henry (ID761) Difficult to get out of Hillside Drive onto Forest Road. With the proposed plans for BIN5 this will get worse with the increase volumes of traffic without better infrastructure improvements

C and A Rivera-Valez (ID491) Access by car from Binfield village is difficult now without any further housing

Davis/Skaife (ID225) Narrow pavements in the centre of Binfield make it difficult for pedestrians to keep out of the road, making any increase in traffic a risk for school children and mothers with prams.

Reeves (ID98) Road is dangerous. Davis (ID225) Access would be difficult to achieve (BIN5 and BIN6). Elliott (ID228) Already difficult to park due to lack of parking space (Forest Road) Watson (ID303) Where are the roads to accommodate new houses? G Ramsay (ID866) It’s not just those who live near the sites that are affected by over

development – on the Stevenson Drive estate it is becoming noticeably harder to get into and out of the village (very difficult to drive down Terrace Road North)

S Bradley (ID639), P Harvey (ID747)

Increase in traffic will disturb the peace / impact health and wellbeing

Coker (ID157) Where will parking for construction / contractors be? Underhill (ID457) likely that residents' parking on Forest Road would have to be

restricted to improve traffic flow; this will be extremely controversial for property owners on Forest Road who lack off-street parking.

Graham (ID230) The increase in traffic, as an alternative exit for the new education village will be considerable.

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B Runham (ID171) Murrell Hill Lane used to by pass the village centre was closed to through traffic, why not reopen this.

Rawsthorne (ID173), Higgins To mitigate impact, suggest a parking layby for dwellings on Forest (ID174), Brown (ID389), ), Prior Road is provided opposite the proposed site. Need somewhere to (ID390), Ludlam (ID414), C and park car off the road. L Prior( (ID931), R Woolford (ID998), O Brown (ID1356), P Hadley (ID1357) E and B Glasson (ID974) Changes aimed at accommodating more traffic, or providing all the

other services which will be needed, will be, either unaffordable for the Council or will finally eliminate what remains of the village local residents cherish.

R Woolford (ID998), Concern where delivery drivers will park when Forest Road full of construction vehicles

S Carter (ID1222), D Carter (ID1223)

The Local plan proposes “minimal reliance on the private car” and locating sites “so as to reduce the need to travel”. All these new sites in the area are bring cars since public transport is not fit for purpose with too few buses at the times people need to travel to and from work. Need to consider upgrading public transport before building more houses.

INFRASTRUCTURE

Evans (ID159), Graham (ID230), Cumulative effect / impact of development /over development is not Ketley (ID231), Lunn (ID234); sustainable – increase on services (traffic, roads, water supply, Harris (ID301), L. Page (ID304), drainage, sewers, public services, pollution, doctors (already over N. Page (ID306), A. Page subscribed), local amenities) cannot be met. (ID310), Underhill (ID457), Harvey (ID458), E. Harvey (ID472), R. Glover (ID475), P. Glover (ID478), Bryant (ID490), C and A Rivera-Valez (ID491), M Kentish (ID493), N and F Moynihan (ID494), Shirley (ID497), Hutton (ID504), V Baker (ID514), K Dagnall (ID515), R Davies (ID522), Leakey (ID519), A Kelly (ID523), Stilgoe and Holdford (ID533), J Unwin (ID534), A and Cocking (ID536), R Warren (ID540), R Baloch (ID542), A Glover (ID550), A Baylis (ID553), K Baylis (ID568), K Wilson (ID590), K Aherne (ID592), P Maddox (ID604), A and C Whitney (ID610), E T Bradley (ID619)Bradley (ID611), T User (ID629), T Chizlett (ID645), N Wilson (ID657), S and E Whatley (ID732), P Barton

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(ID741), A and R Lambourn (ID744), B Wetherall (ID746), P Kendall-Savegar (ID748), C and L Jacobs (ID757), M Goodwin (ID760), P Chizlett (ID810), K Williams (ID863), G Boorman (ID869), C Boorman (ID872), C and S Palmer (ID934), R Baloch (ID745), D Chidwick (ID1039), G Gibson (ID1048), J Harvey (ID1099), S Carter (ID1222), D Carter (ID1223), Z Baloch (ID1295), J Wilmott (ID1309), D Kiernan (ID1340), A Reynolds (ID1342), N Glover (ID521) Doctors surgery overstretched and impractical to expand so will need

a new one which would be complicated to establish fair catchments. M Kentish (ID493) Strain on the local amenities as same number of facilities available

therefore it will become harder to get doctors appointments, parking etc. The developments will take far more from the local community than they are able to contribute.

Davis/Skaife (ID225) Ad hoc development (BIN5 and BIN6) multiplies the risk that other services e.g. water, schools will not be able to cope with the increased demand and result in unforeseen consequences.

R Kentish (ID496), R Baloch (ID745)

Classified by the Environmental Agency as an area of serious water stress. Threatens right to water.

A and R Lambourn (ID744), Further pressure will be put on water supply in a water deficit area. As long as we are operating under the EU Water Framework Directive there is the likelihood of compulsory metering, and standpipes in times of shortage, will greatly increase (the Directive stipulates these measures to be taken first, rather than capital intensive projects undertaken, such as pipelines or reservoirs). This places further unnecessary problems for homeowners, particularly those with children and the elderly.

Watson (ID303) Where is the infrastructure? G Ramsey (ID866) Not the infrastructure in place to support the existing population, let

alone several hundreds more C and S Palmer (ID934) Not yet felt the impact of the new school and houses OTHER MATTERS

Lunn (ID234); Watson (ID303), N Glover (ID521), Preston (ID481), A and R Lambourn (ID744), E Harvey (ID472), J Harvey (ID1099), Wilson (ID590), Wilson (ID657), Lambourn (ID744), E and B Glasson (ID974), J Clark (ID976), Ramsey (ID866), Z Baloch (ID1295), P Fennel

The Council has gone back / reneged on its covenant / policy for Blue Mountain golf course

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(ID1341), J Blamire (ID994)

T Bradley (ID619) Been lied to regarding development round Binfield and will fight development of BIN5 and BIN6 to high court

S Runham (ID495) If the Councillors go back on their word to protect area then they have lost their integrity.

D Chidwick (ID1039) Does the department agree that disregard for previous commitments (sites would be left as open space when Blue Mountain developed) destroys the publics trust in the planning process in Bracknell? Would the council and planning department expect residents to be able to trust any future commitments or statements it makes regarding planning in Bracknell in the future?

J Wilmott (ID1309) The council has already contravened a prior commitment not to build on the golf course and to the commitment not to build on BIN5 and BIN6 would place the Councils concerned and members into further disrepute.

Harvey (ID458), E. Harvey (ID472)

Wish the Council would make a decision which is representative of the community – not one that benefits developers as with the overturning of Blue Mountains protected status.

J Clark (ID976) Blue Mountain planning application left the sites (BIN5 and BIN6) out of the plans. Suspicious that this was the plan by Luff Developments and the Council all along.

R. Glover (ID475) If proceed with development on these sites there is a real possibility of legal action

A Glover (ID550), Large number of people will threaten close community K Baylis (ID568), House will be devalued and new ones will be buy to lets. A and C Whitney (ID610), C and L Jacobs (ID757)

House prices will decrease

Burrowes and Henry (ID761) Concerned as paid a premium to live Binfield G Ramsey (ID866) Price of new houses will be out of reach of local young people S and D Carter (ID1222 - 1223) Moved to Binfield as it was a peaceful and attractive area with lots of

open space, yet this is being systematically eroded by the Borough’s development plans.

V Baker (ID514) Sites do not fit within policy framework and negative impacts outweigh benefits/

P Maddox (ID604) Questionable whether sufficient attention has been paid to Policy LP18 – Design (vii) to ‘Include adequate, high quality, usable public and private open space’, considering the proposed housing counts of 34 (BIN6) and 40 (BIN5).

S Clark (ID655) Sites (BIN5 and BIN6) are Grade 3 agricultural land. Further inspection needed to see if it is Grade 3a, land that is ‘best and most versatile’ and subject to National Planning Policy Framework and Guidance. (Extracts from NPPF).

C and L Jacobs (ID757) Understandably this has created suspicion (assurances that BIN5 and BIN6 would be open space / SANG) that it may have been a deliberate move of Luff and was part of their overall development plan from the beginning. Despite our attempt to find out what was happening with both sites over the last 13 months, details have been made very ambiguous and difficult to decipher. We feel deceived

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and let down by Bracknell Forest Council on this.. J Clark (ID976) What is the relationship between Bracknell Forest Council and Luff

Developments? Sites (BIN5 and BIN6) were originally promised as SANG only to be removed from the final planning application. Also Luff Developments have bought a house just next to BIN6. How can they be so sure that a planning application on this field will be approved? Have the Council given them some sort of reassurance? Removing Bin 5 and 6 from the Local Plan will send a strong signal that the Council are operating ‘above board’ and not colluding with developers.

A and M D’Aubyn (ID995) Main sewer running diagonally across site. J Maloney (ID1358) Soil type which is problematic for development in a previous survey

for possible allocated sites in Binfield. Disturbing the clay soil could pose a subsidence risk for the surrounding properties, as well as creating drainage issues.


Boyer on behalf of Luff In June 2016, Luff gained planning permission for “up to 400 Developments (ID1324) additional dwellings, a community facility, sports provision and open

space and full consent was gained for an all through school (Learning Village), approximately 13 hectares of Suitable Alternative Natural Greenspace (SANG), vehicular accesses from Temple Way, a spine road (known as Avenue A) through the development and a school drop off/SANG car park.”

Following the grant of planning permission Luff transferred the “Learning Village” land to BFC, the area with outline planning permission for housing SANG to Bloor Homes and Linden Homes.

Luff have retained the remainder of the site (Land West of Wood Lane) as well as the excess SANG capacity (over 4 hectares of SANG land). This excess capacity can be utilised for mitigation on land owned by Luff. Luff own two sites adjacent to the Blue Mountain site; known as Land south of Forest Road and east of Cheney Close (BIN5) and Land south of Emmets Park and east of Cressex Close (BIN6).

Bin5 is accessed directly off Forest Road. Trees located along the site boundaries, including 3 Oak trees covered by TPOs (Initial master planning work shows that a new entrance could be created, west of the trees to ensure their retention as part of any development.) The site is within Flood Zone 1. There are no statutory or non-statutory nature conservation designations for the site. The site is relatively flat.

BIN5 and BIN6 both formed part of the original Blue Mountain allocation in Policy SA7 of the Site Allocations Local Plan (SALP) (2013). (extract from Policy SA7).

The principle of development on BIN5 and BIN6 has therefore

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already been established. However, the Blue Mountain planning permission did not include BIN5 and BIN6 within the red line.

The full quantum of the 400 dwellings allocated by SALP Policy SA7 were shown within the red line area and Indicative Masterplan of the hybrid planning permission (ref. 16/00020/OUT). Therefore, whilst the principle of development is considered acceptable the amount of development appropriate for BIN5 and BIN6 needs to be established by the new Local Plan.

Boyer estimated a capacity for BIN5 of 42 dwellings and for BIN6 of 40 dwellings, both at an approximate density of 25 dwellings per hectare. In November 2016, the results of the Council’s initial assessments were released as part of the Strategic Housing and Economic Land Availability Assessment (SHELAA). The SHELAA assessments estimated the capacity of BIN5 as 50 dwellings and BIN6 as 42 dwellings. Boyer supported these estimated capacities.

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Responses to Section: 6.2. Residential/mixed use development/Policy LP3. Site BIN6 – Land south of Emmets Park and east of Cressex Close


Site BIN6 – Land south of Emmets Park and east of Cressex Close





Binfield Parish Council (ID254) Trees with TPOs at the proposed entrance to the site. Binfield Parish Council (ID254) Adders, grass snakes, slow worms and bats have been seen on the

site. Binfield Parish Council (ID254) The site is boggy, especially at the bottom of the hill by the gardens

of Emmets Park (bog plants grow well in these gardens) and standing water is often visible in the field.

Binfield Parish Council (ID254) Japanese Knotweed is present on the site close to the Cressex Close dwellings.


Binfield Parish Council (ID254) Strongly opposes development on the site (reasons listed under the appropriate sub-headings).

Binfield Parish Council (ID254) Residents are strongly opposed to development on the site. When the development of Blue Mountain was proposed, residents were promised that the site would form part of the open space surrounding Blue Mountain to help mitigate that development. Residents and feel strongly that the Borough Council should keep that promise.

Binfield Parish Council (ID254) Site entrance is proposed to be through Emmets Park, which will put additional pressure on the exit from Emmets Park onto Forest Road, which has become very busy with traffic from the new developments in Wokingham. Emmets Park is a quiet residential road and additional traffic will put undue pressure on the road and on residents.

Binfield Parish Council (ID254) The dwellings overlooking the site from Cressex Close are all bungalows. Height restrictions have been placed on extensions in Cressex Close because of overlooking and unneighbourly issues. It would be difficult for development not overlook these properties.





Evans (ID159), Smith (ID161), Davis/Skaife (ID225), Elliott (ID228), Graham (ID230), Ketley (ID231), Fraser (ID232), Lunn (ID234), Weber (ID235),

Building on the site will not maintain significant land / gap between development (Binfield and Bracknell). Previously led to believe / assured / promised by Council / conveyancers / searches that BIN5 and BIN6 would be maintained as green space/SANG to separate Binfield from Bracknell (Development Plan / Policy SA7 / Binfield

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Wallace (ID247); Harris (ID301), Watson (ID303), L. Page (ID304), N. Page (ID306), A. Page (ID310), S.W. Kelly (ID326), Underhill (ID457), Harvey (ID458), E. Harvey (ID472), Andrews (ID473), R. Glover (ID475), P. Glover (ID478), Preston (ID481), J and C Sinclair (ID489), Bryant (ID490), N and F Moynihan (ID494), R Kentish (ID496), S Runham (ID495), Shirley (ID497), Whelan (ID499), Hutton (ID504), Higgins (ID505), V Baker (ID514), K Dagnall (ID515), Leakey (ID519), N Glover (ID521), R Davies (ID522), Heyes (ID524), G Baker (ID525), T Baker (ID527), W Low (ID528), Stilgoe and Holdford (ID533), J Unwin (ID534), A and S Cocking (ID536), R Warren (ID540), R Baloch (ID542), K Long (ID 549) A Glover (ID550), A McFaul (ID551), A Baylis (ID553), A Osborn (ID555), K Baylis (ID568), K Wilson (ID590), K Aherne (ID592), P Maddox (ID604), S Kelley (ID609), A and C Whitney (ID610), R Willmott (ID618), T Glover (ID620), T User (ID629), T Chizlett (ID645), S Clark (ID655), N Wilson (ID657), S and E Whatley (ID732), Sibley (ID734), A and R Lambourn (ID744), P Harvey (ID747), P C and L Jacobs (ID757), Kendall-Savegar (ID748), C and L Jacobs (ID757), M Goodwin (ID760), P Chizlett (ID810), L Harris (ID859), G Ramsey (ID866), G Boorman (ID869), C Boorman (ID872), C and S Palmer (ID934), M Long (ID935), Chalmers and Taylor-Cutter (ID940), E and B Glasson (ID974), J Clark (ID976), J Blamire (ID994), R


Neighbourhood Plan / Section 52 Planning Agreement for Blue Mountain) when Blue Mountain was developed and Council has gone back on its promise.

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Baloch (ID745), D Chidwick (ID1039), G Gibson (ID1048), J Harvey (ID1099), G Buffet (ID1100), J Sones (ID1248), Z Baloch (ID1309), D Kiernan (ID1340), P Fennel (ID1341), A Reynolds (ID1342), J Maloney (ID1358) H, F and S Farthing (ID612), N Sites (BIN5 and BIN6) separate Bracknell / Blue Mountain from Hanson (ID656), Reeves Binfield. Building on them will not maintain significant gap / green belt (ID104), Marriott (ID156), C and will and merge Bracknell and Binfield, losing the village identity. A Rivera-Valez (ID491), S Byron (ID736), A and R Lambourn (ID744), A and E D’Aubyn (ID995), J Harvey (ID1099), J Wilmott (ID1309), J Norfolk (ID1339), P Fennel (ID1341) S Clark (ID655) Sites (Bin5 and Bin6) form part of the Local Gap between Bracknell

and Binfield. This Local Gap was identified in the Inspector’s report in 2007 and the Adopted Core Strategy of 2008 and the Inspector’s Report of 2013. The Blue Mountain Golf Course helped to maintain this recognized Local Gap, but as a result of Policy SA7 this Local Gap has been severely degraded. Development of sites Bin5 and Bin6 would further degrade this Local Gap in direct contravention of Policy SA7, Inspector’s Reports of 2007 and 2013 and Bracknell Forest Council’s Adopted Core Strategy - February 2008. (extracts from Site Allocations Local Plan 2013, Bracknell Forest Council Site Allocations Local Plan, Inspectors Report June 2013, Bracknell Forest Borough Council LDF – Core Strategy DPD Examination – Inspector’s Report 2007, Core Strategy 2008

S Clark (ID655) In contravention of Inspectors Report of 2007 (Core Strategy DPD examination) 2008 and 2013 (Site Allocations Local Plan) which clearly suggest that the development of the land should be to the South of the Blue Mountain site and not to the North where sites Bin5 and Bin6 are located. (extracts from above reports)

S Clark (ID655) The defined settlement boundary for Binfield does not include Sites Bin5 and Bin6. Moving the boundary to include these sites further degrades the defined local gap and visual separation between Binfield and Bracknell as identified in Inspector’s Report of 2013. It would also be in direct contravention to Bracknell Forest Council’s Core Strategy 9. (extracts from Core Strategy 2008 and Site Allocations Local Plan Inspectors Report 2013)

V Baker (ID514) Difficult to see how development will meet criteria (extract of Policy LP12 - Landscape character and strategic gaps)

P Maddox (ID604) Sites (BIN 5 and BIN6) form part of the gap between Binfield and Bracknell - Section 5.25 “to prevent neighbouring towns merging into one another” and Section 11.2 / Policy LP12 ‘Landscape character and strategic gaps’.

S Carter (ID1222), D Carter Developing the sites (BIN5 and BIN6) will remove the strategic green

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(ID1223) gap between Bracknell and Binfield. The Local Plan states that developments should “enhance the natural and historic environment, including landscape.” How is this the case if you develop these sites?

C and L Jacobs (ID757) The Binfield Landscape Character Assessment recommends that the gap be maintained in order to conserve the open and rural character of Binfield.

A and M D’Aubyn (ID995) The argument that these sites (BIN5 and BIN6) just fill in boundary gaps only shows the misunderstanding of the nature of an English village and what it means to the inhabitants. Symmetry and neatness planning terms not residents

Evans (ID159), Smith (ID161), Contrary to Policy CS2 and NPPF as brownfield should be utilised / Davis/Skaife (ID225), Ketley prioritised over green field sites. Brownfield sites have come forward (ID231), Lunn (ID234), Weber which have not been included. Many available in Bracknell / the (ID235), Harris (ID301), S.W. Borough suitable for development including empty offices / Kelly (ID326), Harvey (ID458), commercial buildings. E. Harvey (ID472), R. Glover (ID475), P. Glover (ID478), Preston (ID481), J and C Sinclair (ID489), Bryant (ID490), M Kentish (ID493), R Kentish (ID496), Shirley (ID497), Whelan (ID499), Higgins (ID505), N Glover (ID521), R Davies (ID522), Heyes (ID524), G Baker (ID525), T Baker (ID527), W Low (ID528), Stilgoe and Holdford (ID533), J Unwin (ID534), R Warren (ID540), A McFaul (ID551), A Baylis (ID553), A Osborn (ID555), K Baylis (ID568), K Aherne (ID592), P Maddox (ID604), S Kelley (ID609), A and C Whitney (ID610), R Willmott (ID618), T Chizlett (ID645), A and R Lambourn (ID744), C and L Jacobs (ID757), M Goodwin (ID760), P Chizlett (ID810), K Williams (ID863), G Ramsey (ID866), G Boorman (ID869), C Boorman (ID872), Chalmers and Taylor-Cutter (ID940), E and B Glasson (ID974), J Clark (ID976), R Baloch (ID745), D Chidwick (ID1039), J Harvey (ID1099), S Carter (ID1222), D Carter (ID1223), Z Baloch (ID1309), D Kiernan (ID1340), J Maloney (ID1358)

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K Dagnall (ID515), T Bradley (ID619), H, F and S Farthing (ID612), T Glover (ID620), N Hanson (ID656), P Kendall-Savegar (ID748), J Sones (ID1248)

Should focus/develop on brownfield sites.

J Blamire (ID994), Should develop brownfield before Green Belt. The government attach importance to the Green Belt (extract NPPF)

A and E D’Aubyn (ID995) Questions why greenfield sites are being put forward before brownfield – builder favour them

V Baker (ID514) NPPF states that Brownfield sites should be considered and the draft NPPF (consultation March 2018 paragraph) states that local planning authorities should take a proactive role in identifying and helping bring forward land for development. Why isn't the Council looking at this rather than small sites (BIN5 and BIN6) where you can fit a small percentage of houses in comparison to the need?

J Clark (ID976) Council should be more pro-active about thinking about future brownfield sites that may come forward and develop green space like Bin 5 and Bin 6 when another large development opportunity may be around the corner. The next version of the NPPF will require Councils to be more pro-active in searching for brownfield sites.

Watson (ID303) What about the commitment to the Green Belt? B Wetherall (ID746) Green Belt in danger of disappearing CHARACTER

Crawford (ID80) Not opposed to development of the site, but any proposal should be in keeping with existing development and density. An appropriate number would be 15/16 based on the area available.

Coker (ID157) Whilst not a consideration at this time, development should match the existing dwellings in Emmets Park, to provide cohesion with this part of Binfield.

Reeves (ID98) Site not suitable for allocation, will destroy the village / loss of village amenity.

L. Page (ID304), N. Page (ID306), A. Page (ID310)

Village should be protected not destroyed by over development of green space.

Runham (ID172) Consideration should not be given to this site in isolation, but impact upon the character, taking account of other development in Binfield.

Runham (ID172) Little visible green space remaining near the village centre, should be retained to maintain village character (taking into consideration development at Blue Mountain).

Fern(ID226) Loss of green space would lead to the irreversible loss of character and value to the community on a mental health and well being level. Avoiding over development and incorporating planting of trees etc. would go some way to mitigate this. Important to get the aesthetics right.

Bradley (ID480) Will make Binfield ugly Evans (ID159), Smith (ID161), Elliott (ID228); Ketley (ID231); Weber (ID235), Wallace (ID247), E. Bradley (ID312),

The sites (BIN 5 and BIN6) forms part of the rural character / tranquillity / peace / sense of place / identity of the village. Just be an extension of Bracknell.

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S.W. Kelly (ID326), Harvey (ID458), E. Harvey (ID472), Andrews (ID473), P. Glover (ID478), Preston (ID481), M Kentish (ID493), S Runham (ID495), Shirley (ID497), Whelan (ID499), Hutton (ID504), Higgins (ID505), V Baker (ID514), K Dagnall (ID515), A Kelly (ID523), Heyes (ID524), G Baker (ID525), T Baker (ID527), J Unwin (ID534), A and S Cocking (ID536), R Warren (ID540), R Baloch (ID542), A Glover (ID550), A McFaul (ID551), A Osborn (ID555), K Aherne (ID592), E Bradley (ID611), H, F and S Farthing (ID612), R Willmott (ID618), T Bradley (ID619), T Glover (ID620), S Bradley (ID639), N Wilson (ID657), S and E Whatley (ID732), A and R Lambourn (ID744), B Wetherall (ID746), C and L Jacobs (ID757), M Goodwin (ID760), C Reynolds (ID762), K Williams (ID863), G Ramsey (ID866), C and S Palmer (ID934), M Long (ID935), J Clark (ID976), R Baloch (ID745), J Harvey (ID1099), G Buffet (ID1100), D Kiernan (ID1340), P Fennel (ID1341) Smith (ID161), R Kentish (ID496),

Emmets Park and Emmets Nest are quiet residential cul-de-sacs, character will be destroyed by making Emmets Park a through road.

Smith (ID161), Binfield Parish The site is on a steep slope, and new dwellings will overlook / Council (ID254), Harris (ID301), compromise privacy / peace / take away natural light of existing S.W. Kelly (ID326), Underhill residents of Emmets Park / Cressex Close. (ID457), R. Glover (ID475), P. Glover (ID478), S Runham (ID495), Higgins (ID505), V Baker (ID514), N Glover (ID521), R Warren (ID540), K Long (ID 549), A Glover (ID550), A Osborn (ID555), K Wilson (ID590), K Wilson (ID590), K Wilson (ID590), S Kelley (ID609), A and C Whitney (ID610), T Glover (ID620), A

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and R Lambourn (ID744), Davis/Skaife (ID225), Higgins (ID505), R Warren (ID540), K Long (ID 549), C and L Jacobs (ID757), K Williams (ID863), G Ramsey (ID866), G Boorman (ID869), C Boorman (ID872), E and B Glasson (ID974), S Butcher (ID982), R Baloch (ID745), A and M D’Aubyn (ID995), J Harvey (ID1099), S Jones (ID1295), Z Baloch (ID1309) Davis/Skaife (ID225), S Runham (ID495), C and L Jacobs (ID757)

Cressex Close is bungalows and new development is unlikely to be restricted to single-story buildings resulting in overlooking by taller buildings and loss of privacy

S Runham (ID495) Such overbearing structures run contrary to Local Plan policy EN20 and BF1 of Binfield Neighbourhood Plan.

S Runham (ID495) Overlooking of houses on Emmets Park I. Searle (ID465) Would prefer to see bungalows. Tall buildings would be above the

viewing line of the properties at the east end of Cressex Close i.e. houses 27-33 inclusive. If two storey buildings were to be built, they should be at the eastern end of the plot with bungalows at the western end.

S Butcher (ID982) Current residents in Cressex Close have been denied permission to add roof structures because they are detrimental to the character and visual amenity of the area and would result in an unacceptable loss of privacy to neighbours. Such overbearing structures run contrary to Local Plan policy EN20 and BF1 of Binfield Neighbourhood Plan.

V Baker (ID514), C and L Cressex Close residents all live in Bungalows and a number of Jacobs (ID757), J Sones owners have had planning permission denied to extend up by (ID1248) 600mm, the council siting reasons that it would not be in keeping

with the character of the area (contrary to Policy CS7 of the Core Strategy Development Plan Document, 'Saved' Policy EN20 of Bracknell Forest Borough Local Plan, Policy BF1 of the Binfield Neighbourhood Plan, the Character Area Assessments SPD, and the National Planning Policy Framework). Question how you can consider building on BIN 6 as would not be in keeping with the local character of the area and contradict Council’s reason for refusal.

V Baker (ID514) Development would not be able to uphold criteria x. and xi of LP Policy LP18 – Design

P Maddox (ID604) Questionable whether sufficient attention has been paid to Policy LP18 – Design (vii) considering the proposed 34 houses.

P Maddox (ID604) Outlook that will be lost by development of BIN6, and due to the rising nature of the site will have an overly adverse impact under the considerations of Policy LP18 – Design, including, but not limited to, its ‘location and surroundings through their siting, height and scale’.

C and L Jacobs (ID757) Fail to see how development of BIN6 will meet criteria of Policy LP18 – Design (1st para and v.)

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Green (ID229), Watson (ID303); Shirley (ID497), Whelan (ID499), Heyes (ID524), J Unwin (ID534), K Long (ID549), N Hanson (ID656), S Byron (ID736), P Barton (ID741), G Ramsey (ID866), M Long (ID935), Z Baloch (ID1309), J Maloney (ID1358)

Overdevelopment of the area / loss of village identity (BIN5 and BIN6) / too many recent developments (Tilehurst Lane, Murrell Hill Lane, Blue Mountain).

S.W. Kelly (ID326) As the site is banked housing development at the top of the site will be visible for significant distances.

R Baloch (ID745) Purchased house due to view of hill Davis/Skaife (ID225), C and L Jacobs (ID757)

It has been accepted (Planning Inspectorate decision) that the brick wall at the back of Cressex Lodge and Close represents a natural settlement boundary.

E and B Glasson (ID974) Past development has eradicated many very old and familiar buildings and substantially detracted from the essential character of the village. The southern part of the Parish, unrecognisable.

HOUSING

Reeves (ID98), Ketley (ID231), Lunn (ID234); Harris (ID301), Underhill (ID457), R. Glover (ID475), P. Glover (ID478), P. Glover (ID478), R Kentish R Davies (ID522) (ID496), Higgins (ID505), R Davies (ID522), Heyes (ID524), W Low (ID528), J Unwin (ID534), R Warren (ID540), K Wilson (ID590), K Aherne (ID592), P Maddox (ID604), A and C Whitney (ID610), T Chizlett (ID645), N Wilson (ID657), S and E Whatley (ID732), P Kendall-Savegar (ID748), C and L Jacobs (ID757), P Chizlett (ID810), K Williams (ID863), M Long (ID935), J Clark (ID976), D Chidwick (ID1039),

Small gain in housing numbers compared to impact.

Davis/Skaife (ID225) Don’t believe it was intended to be government policy to bulldoze through development. Sites (Bin5 and Bin6) will provide a small number of homes for millionaires with expensive social housing.

Wallace (ID247) Housing should not be approved at the expense of the existing community.

E. Bradley (ID312) Not opposed to building houses but the Council needs to find more suitable locations

V Baker (ID 514) No change in housing demand since assured that BIN5 and BIN6 were SANG. This is evidenced by the new properties on Terrace Road South which are still up for sale. Has the Council has

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considered the impact of Brexit on the plan for our area in particular as regards population and economic development?

R Warren (ID540) Current plans already exceed the requirements for new homes therefore there is no justification to include any extra development in Binfield.

G Ramsey (ID866) Believe have met/ exceeded, the Government’s quota for housing. If so any new housing developments are superfluous. The area is now in danger of becoming seriously over developed.

E and B Glasson (ID974) Local communities are being threatened by more development, the amount of land in the Draft Local Plan exceeds the amount of land needed according to the Council’s own housing need assessment.

G Gibson (ID1048) Number of other less intrusive sites which will not have such a detrimental effect on Binfield, its services or the residents.

Leakey (ID519) Should refuse permission until the properties that are being built now have been completed and lived in for a while and review the situation at a later time.

A and R Lambourn (ID744) This further development is being proposed before the impact of new development is known. Better to pause development in this area of Binfield until the Council can properly assess the impact on infrastructure, society / village structure / fabric, and urban / rural landscape to incorporate wisdom and experience into future planning decisions. Without this could be construed as environmental vandalism.

J Harvey (ID1099), S Carter (ID1222), D Carter (ID1223)

Binfield taken heavy share / fair share of new housing over last few years


Lunn (ID234), Preston (ID481), R Kentish (ID496), Higgins (ID505), R Davies (ID522), R Warren (ID540), K Aherne (ID592), P Maddox (ID604), T Chizlett (ID645), C and L Jacobs (ID757), P Chizlett (ID810), J Clark (ID976), D Chidwick (ID1039), D Kiernan (ID1340),

Important to the character and setting of Binfield village which has over 70 / 73 / 708 listed structures/heritage assets

E. Bradley (ID312), E Bradley (ID611),

Fields part of the historic environment/ name of village.

Hutton (ID504) Over development out of character in a village of multiple listed buildings


C and L Jacobs (ID757) Sites (BIN5 and BIN6) are areas of high archaeological potential, which should also be respected and preserved.

C and L Jacobs (ID757) There is an orchard wall that runs along the bottom of the back gardens of Cressex Close and alongside the bridle path, which is a listed wall

NATURAL ENVIRONMENT (biodiversity, designated sites, green infrastructure, Thames Basin

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Heaths Special Protection Area)

Reeves (ID98), Evans (ID159), Impact on trees / TPOs, protected / established / ancient hedgerows / Ketley (ID231), Lunn (ID234); woodland and ancient meadows. Harris (ID301), S.W. Kelly R. Glover (ID475) (ID326), P. Glover (ID478), Preston (ID481), Bryant (ID490), M Kentish (ID493), N and F Moynihan (ID494), R Kentish (ID496), S Runham (ID495), Higgins (ID505), V Baker (ID514), K Dagnall (ID515), N Glover (ID521), R Davies (ID522), W Low (ID528), J Unwin (ID534), A and S Cocking (ID536), R Warren (ID540), R Baloch (ID542), K Long (ID 549), A Glover (ID550), A McFaul (ID551), A Baylis (ID553), A Osborn (ID555), K Baylis (ID568), K Wilson (ID590), K Aherne (ID592), P Maddox (ID604), S Kelley (ID609), T Chizlett (ID645), S Clark (ID655), N Wilson (ID657), S Byron (ID736), P Kendall-Savegar (ID748), C and L Jacobs (ID757), M Goodwin (ID760), P Chizlett (ID810), K Williams (ID863), G Boorman (ID869), C Boorman (ID872), Chalmers and Taylor-Cutter (ID940), E and B Glasson (ID974), J Clark (ID976), R Baloch (ID745), D Chidwick (ID1039), G Gibson (ID1048), S Carter (ID1222), D Carter (ID1223), Z Baloch (ID1309), D Kiernan (ID1340), J Maloney (ID1358) Reeves (ID98), Coker (ID157), Impact to wildlife / habitat for wildlife / plants (comments refer to the Evans (ID159); Ketley (ID231), following: deer (roe and muntjac), foxes, grass snakes, toads, field Lunn (ID234); Harris (ID301), mice, voles, butterflies, moths, birds (incl. pheasants, red kites, Watson (ID303), E. Bradley ospreys, birds of prey, owls), bats, adders, slow worms, hedgehogs, Andrews (ID473) (ID312), S.W. wild flowers, insects, horses, wetland species, newts, ponies, rabbits Kelly (ID326), R. Glover (ID475), P. Glover (ID478), Bradley (ID480), Preston (ID481), Bryant (ID490), M

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Kentish (ID493), N and F Moynihan (ID494), R Kentish (ID496), S Runham (ID495), Shirley (ID497), Higgins (ID505), Drew (ID509), V Baker (ID514), K Dagnall (ID515), N Glover (ID521), R Davies (ID522), Heyes (ID524), W Low (ID528), J Unwin (ID534), A and S Cocking (ID536), R Warren (ID540), K Long (ID 549) A Glover (ID550), A McFaul (ID551), A Baylis (ID553), A Osborn (ID555), K Baylis (ID568), K Wilson (ID590), K Aherne (ID592), P Maddox (ID604), S Kelley (ID609), A and C Whitney (ID610), E Bradley (ID611), T Bradley (ID619), T Glover (ID620), S Bradley (ID639), T Chizlett (ID645), N Hanson (ID656), N Wilson (ID657), S and E Whatley (ID732), Sibley S Byron (ID736), (ID734), C and L Jacobs (ID757), M Goodwin (ID760), C Reynolds (ID762), P Chizlett (ID810), L Harris (ID859), K Williams (ID863), G Boorman (ID869), C Boorman (ID872), H Jackson (ID884), Chalmers and Taylor-Cutter (ID940), E and B Glasson (ID974), J Clark (ID976), R Baloch (ID745), D’Aubyn (ID995), D Chidwick (ID1039), G Gibson (ID1048), S Carter (ID1222), D Carter (ID1223), J Sones (ID1248), Z Baloch (ID1309), D Kiernan (ID1340), P Fennel (ID1341), J Maloney (ID1358) H Jackson (ID884) Given the substantial building in this area (west end for example) the

local wild life has moved into this area. Willing to engage with the Council to protect the habitat


Provision must be made in the area for species support and protection given the amount of development

Andrews (ID473) Hedgerows support a large variety of bird (including Nuthatches, Goldfinches, Goldcrests, Long-tailed tits, Lesser Spotted

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Woodpeckers, Green Woodpeckers, Fieldfares and Sparrowhawks) E and B Glasson (ID974), NW corner of the field there was once a pool. Still damp enough to

provide habitat for frogs and toads C and L Jacobs (ID757) Policy LP18 – Design criteria iii states that all new developments must

“retain and, where reasonable, enhance existing trees, important open areas, gaps in frontages, hedgerows, walls, fences, banks and other site features of landscape, ecological, heritage or amenity value.” Proposing to build on the sites (Bin 5 and Bin 6) will significantly reduce, ruin and negatively impact the wildlife, existing trees, hedgerows, walls, banks, grassland and little scrub land that Binfield has left.

Reeves (ID102) The site contains all aspects referred to in section 17.1.3, ignoring this and building on the site is not sustainable or green.

Davis/Skaife (ID225), T Glover (ID620), E and B Glasson (ID974), J Wilmott (ID1309)

Last remnants / remaining areas of a natural environment/open space in Binfield (with BIN6).

Davis/Skaife (ID225), C and L Jacobs (ID757)

Footpath at the back of the wall in Bin6 needs to be respected and considered in any plan.

E. Bradley (ID312) Sites (BIN5 and BIN6) should be protected as ‘Local Green Space’. Underhill (ID457) This part of Binfield lacks open space for recreation. Should be

designated by the Local Authority for recreational use. P. Glover (ID478), Preston (ID481), C and L Jacobs (ID757)

Should be public right of way / community space / open space.

S Runham (ID495) Important to retain as green space to offset urbanisation around area (Cabbage Hill to Amen Corner North and South)

Andrews (ID473) Natural green space, far more valuable as a wildlife corridor than park-style spaces.

Banks (ID19) The site would be better added to the public access area designated below the golf course, green spaces needed.

J Clark (ID976), Council should purchase the sites (BIN5 and BIN6) in order to make for public open space.

C and A Rivera-Valez (ID491) Without green spaces feels claustrophobic and overpopulated and vehicle fumes become unbearable and psychological and physical health deteriorate.

S Runham (ID495) Contrary to Policy LP38 - Green Infrastructure as it would fragment green infrastructure and create barriers to the movement of people, biodiversity and water through the green infrastructure network.

Elliott (ID228), P. Glover (ID478), Preston (ID481), S Runham (ID495), N Glover (ID521), A Glover (ID550), A and C Whitney (ID610), H, F and S Farthing (ID612), R Willmott (ID618), P Harvey (ID747), J Clark (ID976)

Children / residents need to experience / spend time in / enjoy / view open green spaces to enhance the quality of their lives / mental health / well being.

Ketley (ID231), Fraser (ID232), Lunn (ID234), Wallace (ID247);

Loss of further open / green space damaging to community / environment which outweighs contribution to housing targets.

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Harris (ID301), Underhill (ID457), R. Glover (ID475), R Kentish (ID496), Whelan (ID499), Hutton (ID504), R W Low (ID528),Davies (ID522), J Unwin (ID534), R Warren (ID540), K Wilson (ID590), K Aherne (ID592), P Maddox (ID604), H, F and H, F and S Farthing (ID612), S Farthing (ID612), T Chizlett (ID645), N Wilson (ID657), S and E Whatley (ID732), P Kendall-Savegar (ID748), C and L Jacobs (ID757), P Chizlett (ID810), G Boorman (ID869), C Boorman (ID872), M Long (ID935), J Clark (ID976), D Chidwick (ID1039), G Gibson (ID1048), J Harvey (ID1099), S Carter (ID1222), D Carter (ID1223), Z Baloch (ID1309), D Kiernan (ID1340), P Barton (ID741) Promised to maintain open spaces E and B Glasson (ID974), At times no boundary between the field and the footpath so accessible

to anyone to enjoy. Was local campaign to make the site a village green.

P Barton (ID741), P Harvey (ID747)

Concern that there will be no green spaces left

Fraser (ID232) Ancient sites (BIN5 and BIN6) where the old oaks from Windsor Forest are still features of our landscape.

E Harvey (ID472), K Andrews Amenity value - used for sledging (ID473), P Glover (ID478), C Preston (ID481), E, J and A Higgins (ID505), F Drew (ID509), G and S Baloch (ID542), T Glover (ID620), C and L Jacobs (ID757), E and B Glasson (ID974), R Baloch (ID745), J Norfolk (ID1339) S.W. Kelly (ID326), S Kelley Severely banked site means it is unsuitable for development without (ID609) environmentally damaging earthworks which will be disruptive and

destructive to whatever environmental mitigation is agreed to by the developers.

Andrews (ID473), P. Glover (ID478), A Glover (ID550), T Glover (ID620),

Footpath which runs alongside Bin6 provides a tranquil walk with views.

K Long (ID549), K Baylis (ID568), E and B Glasson (ID974),

View from top of site

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J Blamire (ID994) Have taken away view of golf course P Maddox (ID604) Contrary to Policy LP1 (iv) to “protect and enhance the natural

environment and heritage assets together with their settings”. (comment also under historic environment)

Whelan (ID499) Understand that developments have to provide sufficient SANG space for the number of units that have been approved. Is this still the case given the amount of development taking place in and around Binfield?

S Clark (ID655) Changing the designation of the land from SANG so soon after the adoption of Policy SA7 and the land’s subsequent planning permission is in direct contravention of the Council’s own decision and the Planning Inspector’s reports of 2007 and 2013. (extracts from Site Allocations Local Plan and Document – SAL110 - Statement of Common Ground: Luff Developments Ltd).

S Clark (ID655) Site is under policy CS14: Thames Basin Heaths Special Protection Area. Site Allocation Local Plan Map 40 shows the land being dissected by the boundary of the Thames Basin Special Protection Area. Whilst this policy does not prevent the development of the land, it does call for sufficient SANG / Open Space to be provided to offset the development. As sites Bin5 and Bin6 have been assigned as SANG / Open Space question appropriateness for development. (extracts from Core Strategy 2008,Site Allocations Local Plan 2013 and SAL110 - Statement of Common Ground: Luff Developments Ltd).

CLIMATE CHANGE/ENVIRONMENTAL SUSTAINABILITY (flooding, drainage, pollution,contamination)

Hayes (ID12) Existing sewage system cannot cope with existing houses, existing sewage flooding, other properties could suffer.

Banks (ID19), S.W. Kelly (ID326)

Concerns regarding water runoff from the site will increase flood risk to Emmets Park.

Reeves (ID98), Marriott (ID156), Coker (ID157), Smith (ID161), Harris (ID301), S.W. Kelly (ID326), R. Glover (ID475), P. Glover (ID478), Hutton (ID505), V Baker (ID514), N Glover (ID521), A Glover (ID550), S Kelley (ID609), G Boorman (ID869), C Boorman (ID872), R Baloch (ID745),D and M D’Aubyn (ID995), J Harvey (ID1099), J Sones (ID1248), Z Baloch (ID1309), P Fennel (ID1341)

Flood risk as site is poorly drained / boggy / has standing water / is water logged after rainfall / snow.

S Runham (ID495) High risk of surface water flooding on Environment Agency flood map J Norfolk (ID1339) Environment Agency surface water flood map shows houses on

Emmets Parks and Cheney Close at risk of flooding J Norfolk (ID1339) Garage floods

Fern (ID226) Consideration given to where all the water would go during wet weather if it can't soak away

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J Norfolk (ID1339) Site at risk of flooding and concerned that home is located between 2 identified flood risk zones (BIN5 and BIN6) and is at risk of flooding.

Hutton (ID505), V Baker (ID514), R Warren (ID540), R Banks (ID548), A McFaul (ID551), S Kelley (ID609), Z Baloch (ID1309),

Building will increase drainage issues / flood risk for existing residents

J Norfolk (ID1339) Property will be at increased risk of flooding from watercourse in back garden/marshy ground and surface water runoff from front if site is developed. Concerned house will be uninsurable and unsellable.

J Sones (ID1248) Existing drains already fail to cope e.g. Hillside Drive and can only deteriorate

B Wetherall (ID746) May be flooding if drains can’t cope. Coker (ID157) SuDS is will be essential. Chalmers and Taylor-Cutter (ID940)

Area around The Stag and Hounds and Wyevale Garden Centre area frequently floods. Additional paved and built up areas in BIN5 and BIN6 areas can only exacerbate this issue and the impact of The Blue Mountain development impact on these areas is yet to be seen. Too much development and will ruin the area’s ability to handle the volume of water after heavy rainfall.

N Glover (ID521) Evidence of subsidence (due to water) R. Glover (ID475) Evidence of subsidence in the existing homes - without building any

more homes Davis/Skaife (ID225), Higgins (ID505), R Warren (ID540), K Long (ID 549), C and L Jacobs (ID757), K Williams (ID863),

Japanese knotweed infestation.

Crawford (ID80) Increased noise and vehicle pollution, nuisance during construction. Crawford (ID80) Increased noise and vehicle pollution after completion. A and R Lambourn (ID744) Problems with current developments in Binfield regarding adequate

drainage of land (e.g. Woodhurst Park green area which is boggy). Poor natural drainage, increased volume and speed of surface run-off and poor maintenance of drainage channels/ditches/gullies contribute to increased volume of surface run-off and quicker delivery into any drainage channels which are often unable to cope. These artificially raised amounts have to be factored in to any development plans. The impervious clay often means that surface water is puddled on the surface causing boggy land. These factors put huge short term strain on drainage systems and often leading to flash flooding (road outside Wyevale Garden Centre, east of the Stag and Hounds, is frequently flooded which is the area where more “concreting over” of the land is going to take place with the already approved pick-up and drop-off zone for the school.

A and R Lambourn (ID744) Pressure on effluent disposal from developing the site risks problems, particularly as the impact of the Blue Mountain development has yet to make itself felt (apparently inadequately sized effluent disposal pipes for the Woodhurst Park development are going to cause problems).


People who are moving to the area will be impacted by the noise pollution from the redirection of air traffic to/from Heathrow. Mobile

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phone service is interrupted and the sound is loud inside the house. Has this been considered in your planning?

TRANSPORT

Banks (ID19), Crawford (ID80), Increased traffic will be unsustainable / unacceptable / increase Marriott (ID156), Evans (ID159) pollution / reduce quality of life and be hazardous for children / Searle (ID160), Runham residents. Already adverse effects such as congestion/busy roads / (ID172), Elliott (ID228), Ketley cars parked on roads/damage to roads and verges from other (ID231), Fraser (ID232), Weber development in the area (Blue Mountain and associated school with (ID235); Harris (ID301), 1800 pupils, Fox Lane area, Tilehurst Lane Area, Woodhurst Corner, Underhill (ID457), R. Glover Amen Corner, estates in Warfield, Wokingham). Roads referred to in (ID475), J and C Sinclair comments: Terrace Road North and South, Forest Road, Emmets (ID489), Bryant (ID490), M Park, Binfield Road, Cheney Close. Kentish (ID493), R Kentish (ID496), S Runham (ID495), Shirley (ID497), Whelan (ID499), King (ID502), Hutton (ID504), Higgins (ID505), V Baker (ID514), Leakey (ID519), N Glover (ID521), A Kelly (ID523), Heyes (ID524), Stilgoe and Holdford (ID533), A and S Cocking (ID536), R Warren (ID540), R Baloch (ID542), A Glover (ID550), K Baylis (ID568), K Wilson (ID590), S Kelley (ID609), A and C Whitney (ID610), E Bradley (ID611), H, F and S Farthing (ID612), R Willmott (ID618), T Bradley (ID619) T Chizlett (ID645), N Hanson (ID656), S and E Whatley (ID732), Sibley (ID734), S Byron (ID736), P Barton (ID741), A and R Lambourn (ID744), B Wetherall (ID746), P Harvey (ID747), C and L Jacobs (ID757), M Goodwin (ID760), C Reynolds (ID762), P Chizlett (ID810), L Harris (ID859), G Boorman (ID869), C Boorman (ID872), C and S Palmer (ID934), Chalmers and Taylor-Cutter (ID940), E and B Glasson (ID974), J Clark (ID976), R Baloch (ID745), D’Aubyn (ID995), J Harvey (ID1099), J Norfolk (ID1339) Chalmers and Taylor-Cutter (ID940)

An integrated traffic plan for Binfield, Wokingham, Warfield and the areas immediate to these cannot be based on a set of data which

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reflects imminent reality. Roads in and around Binfield Village cannot have been assessed of being capable of handling the massive rise in traffic capacity that is due.

M Long (ID935) Forest Road and infrastructure not designed for increased traffic B Wetherall (ID746) Possibility of properties being damaged by traffic Z Baloch (ID1309) The mini-roundabout at the centre of the village cannot sustain the

increase in traffic from Binfield Learning Village let alone BIN5 and BIN6. The recent temporary traffic lights at the mini-roundabout for essential road repairs resulted in long tail backs on Forest Road which would be a daily occurrence with further development

Banks (ID19), Coker (ID157), Safety, nuisance and privacy concerns regarding access to the site, Ketley (ID231); Fraser (ID232), as Emmets Nest is not a through road/is a cul-de-sac, and additional Davis/Skaife (ID225), Lunn traffic would have to go through the estate. (ID234), I. Searle (ID465), S Runham (ID495), L Harris (ID859), Wallace (ID247), Weber Emmets Park / Nest is not suitable / not designed for additional traffic (ID235), Harris (ID301), S.W. / construction traffic and is a safety hazard / dangerous for Kelly (ID326), Underhill (ID457), children/pets (reasons referred to in comments include: road is R. Glover (ID475), P. Glover narrow, steep, winding, bends, quiet, cul-de-sacs, will become rat (ID478), R Kentish (ID496), runs for approx. 70-200 extra cars, no clear visibility onto Emmets Shirley (ID497), Higgins (ID505), Park). Drew (ID509), V Baker (ID514), R Davies (ID522), Heyes (ID524), G Baker (ID525), T Baker (ID527), J Unwin (ID534), R Warren (ID540), R Baloch (ID542), R Banks (ID548), K Long (ID 549), A McFaul (ID551), A Osborn (ID555), K Wilson (ID590), K Aherne (ID592), P Maddox (ID604), S Kelley (ID609), R Willmott (ID618), T Glover (ID620), T Chizlett (ID645), N Wilson (ID657), S Byron (ID736), A and R Lambourn (ID744), B Wetherall (ID746), C and L Jacobs (ID757), P Chizlett (ID810), K Williams (ID863), G Boorman (ID869), C Boorman (ID872), E and B Glasson (ID974), J Clark (ID976), S Butcher (ID982), R Baloch (ID745), G Buffet (ID1100), S Carter (ID1222), D Carter (ID1223), Z Baloch (ID1309), J Norfolk (ID1339), D Kiernan (ID1340), P Fennel (ID1341) J Norfolk (ID1339) Cars on drives have to back out on to Emmets Park, or stop to

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reverse into them. Will be dangerous with 60+ more cars. P. Glover (ID478) If Emmets Nest were used to access Emmets Park it would become

a rat run with cars clogging up streets not designed for such numbers, and ruin the quiet peaceful nature of the area.

Crawford (ID80) The only entrance to the development is a narrow road, which will not be able to cope with additional volume of traffic

C and L Jacobs (ID757), J Harvey (ID1099), Z Baloch (ID1309)

Access limited / poor - narrow road

J Norfolk (ID1339) The Council’s paperwork showed access possible via Emmets Nest, but this is inaccurate. It is only pedestrian or emergency vehicular access from Emmets Nest to Emmets Park. If the proposal’s access report is based on false data it is severely flawed.

Crawford (ID80) Existing development exits onto Forest Road is not designed for increased traffic. Exiting Emmets Park can be difficult due to volumes of traffic and cars parked along Forest Road.

Footpath / right of way to Emmets Nest would need to be opened to traffic as an alternative entry/exit road.

P Kendall-Savegar (ID748) The number of extra cars which will leave Emmets Park and Emmets Nest to exit onto Forest Road which will also have a great deal of extra traffic is likely to make the whole area very dangerous

Fern (ID226) Each new home is likely to have at least one car. The volume of traffic from both sites (BIN5 and BIN6) would increase. If all the new residents had to go through the village it would cause delays both at the bridge end of the village and at Saint Marks church end for all commuting .If they had access via the golf course road it would solve some of that.

J Sones (ID1248) The buildings and road expansion will overload the congested roads leading around and into the site, converting quiet cul-de-sacs into noisy vehicular thoroughfares.

Coker (ID157) Where will the access to the site be? If through Emmets Park, how will this be managed without disruption to residents.

Davis/Skaife (ID225) Access would be difficult to achieve (BIN5 and BIN6). Coker (ID157) Where will parking for construction/contractors be? Davis/Skaife (ID225) Narrow pavements in the centre of Binfield make any increase in

traffic a risk for school children and mothers with prams. Fern (ID226), Safety concerns if accessed via Emmets Park for construction traffic.

Access from the estate side is so close to the existing houses that it would be problematic due to the bottleneck involving pedestrians and residents. Disruption and noise for the residents. Access to the site via the golf course side would be much safer and far less intrusive.

Wallace (ID247), A Glover (ID550),

Emmets Park access for site development vehicles/works would cause severe disruption to existing residents

R Warren (ID540), Access via Emmets Nest would be impossible due to the unsuitability of the lane and as it is a private road owned by existing residents. Increase in traffic would be dangerous for walkers using this designated footpath.

Graham (ID230) The increase in traffic, as an alternative exit, for the new education village will be considerable.

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Wallace (ID247) At what stage of the approval process is the question of site access considered? Is a site given approval and then it is left to the developer to find a way in?

Watson (ID303) Where are the roads to accommodate new houses? Underhill (ID457) It is likely that residents' parking on Forest Road would have to be

restricted to improve traffic flow; this will be extremely controversial for property owners on Forest Road who lack off-street parking.

C and A Rivera-Valez (ID491) Access by car from Binfield village is difficult now without any further housing

Elliott (ID228) Already difficult to park due to lack of parking space (Forest Road). G Ramsay (ID866) It’s not just those who live near the sites that are affected by over

development – on the Stevenson Drive estate it is becoming noticeably harder to get into and out of the village (very difficult to drive down Terrace Road North)

A Osborn (ID555) Residents will be forced to pave property front-aspects to move cars previously parked road-side due to increased traffic.

S Bradley (ID639), P Harvey (ID747)

Increase in traffic will disturb the peace/impact health and wellbeing

Smith (ID161) No traffic management solution which can mitigate the absence of sightlines at 19 and 21 Emmets Park (reference to an appeal decision to development the site c. 20 years ago on this matter).

E and B Glasson (ID974) Changes aimed at accommodating more traffic, or providing all the other services which will be needed, will be, either unaffordable for the Council or will finally eliminate what remains of the village local residents cherish

J Clark (ID976) Site next to historic Wood Lane, an ancient right of way. Since the other side of Wood Lane is being made into a drop-off car park, could the other side of the Lane be left as it?

Reeves (ID98) Road is dangerous. S Carter (ID1222), D Carter

(ID1223) The Local plan proposes “minimal reliance on the private car” and locating sites “so as to reduce the need to travel”. All these new sites in the area are bring cars since public transport is not fit for purpose with too few buses at the times people need to travel to and from work. Need to consider upgrading public transport before building more houses.

INFRASTRUCTURE

Evans (ID159), Graham (ID230), Ketley (ID231), Lunn (ID234), Wallace (ID247); Harris (ID301), L. Page (ID304), N. Page (ID306), A. Page (ID310), Underhill (ID457), Harvey (ID458), E. Harvey (ID472), R. Glover (ID475), P. Glover (ID478), J and C Sinclair (ID489), Bryant (ID490), C and A Rivera-Valez (ID491), M Kentish (ID493), N and F Moynihan (ID494), R Kentish

Cumulative effect / impact of development / over development is not sustainable – increase on services (traffic, roads, water supply / pressure, drainage, sewers, public services, pollution control, doctors (already over subscribed), dentists, schools, local amenities) cannot be met.

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(ID496), Shirley (ID497), Hutton (ID504), Higgins (ID505), V Baker (ID514), K Dagnall (ID515), R Davies (ID522), Leakey (ID519), A Kelly K Baylis (ID568), (ID523), Stilgoe and Holdford (ID533), J Unwin (ID534), A and S Cocking (ID536), R Warren (ID540), R Baloch (ID542), A Glover (ID550), A Baylis (ID553), A Osborn (ID555), K Wilson (ID590), K Aherne (ID592), P Maddox (ID604), A and C Whitney (ID610), E Bradley (ID611), T Bradley (ID619), T User (ID629), T Chizlett (ID645), ), N Wilson (ID657), S and E Whatley (ID732), P Barton (ID741), A and R Lambourn (ID744), B Wetherall (ID746), P Kendall-Savegar (ID748), C and L Jacobs (ID757), M Goodwin (ID760), P Chizlett (ID810), K Williams (ID863), G Boorman (ID869), C Boorman (ID872), C and S Palmer (ID934), J Clark (ID976), R Baloch (ID745), D Chidwick (ID1039), G Gibson (ID1048), J Harvey (ID1099), S Carter (ID1222), D Carter (ID1223), Z Baloch (ID1295), J Wilmott (ID1309), D Kiernan (ID1340), A Reynolds (ID1342), J Maloney (ID1358) N Glover (ID521) Doctors surgery overstretched and impractical to expand so will need

a new one which would be complicated to establish fair catchments. Z Baloch (ID1309), G and S Baloch (ID542)

Binfield Surgery need to expand their infrastructure (or find new larger local premises) to support the already growing local population but surgery grounds reduced due to private development.

M Kentish (ID493) Strain on the local amenities as same number of facilities available therefore it will become harder to get doctors appointments, parking etc. The developments will take far more from the local community than they are able to contribute.

Davis/Skaife (ID225), Ad hoc development (BIN5 and BIN6) multiplies the risk that other services e.g. water, schools will not be able to cope with the increased demand and result in unforeseen consequences.

Watson (ID303) Where is the infrastructure? R Kentish (ID496), R Baloch (ID745)

Classified by the Environmental Agency as an area of serious water stress. Threatens right to water.

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A Osborn (ID555) Southern Water has only recently notified all Binfield consumers that meters will be mandatory because the supply is already under extreme stress and will become unsustainable. Water meters will only partially mitigate the problem; The supplier is obliged to grow infrastructure to meet new developments but they won't have enough water.

A and R Lambourn (ID744), Further pressure will be put on water supply in a water deficit area. As long as we are operating under the EU Water Framework Directive there is the likelihood of compulsory metering, and standpipes in times of shortage, will greatly increase (the Directive stipulates these measures to be taken first, rather than capital intensive projects undertaken, such as pipelines or reservoirs). This places further unnecessary problems for homeowners, particularly those with children and the elderly.

G Ramsey (ID866) Not the infrastructure in place to support the existing population, let alone several hundreds more

C and S Palmer (ID934) Not yet felt the impact of the new school and houses OTHER MATTERS

Searle (ID160), Lunn (ID234); Watson (ID303), E Harvey (ID472), Preston (ID481), N Glover (ID521), Wilson (ID657), A and R Lambourn (ID744), J Harvey (ID1099), Wilson (ID590), Lambourn (ID744), E and B Glasson (ID974), J Clark (ID976), Ramsey (ID866), Z Baloch (ID1295), P Fennel (ID1341), J Blamire (ID994)

The Council has gone back / reneged on its covenant / policy for Blue Mountain golf course / covenant worthless.

T Bradley (ID619) Been lied to regarding development round Binfield and will fight development of BIN5 and BIN6 to high court

S Runham (ID495) If the Councillors go back on their word to protect area then they have lost integrity.

D Chidwick (ID1039) Does the department agree that disregard for previous commitments (sites would be left as open space when Blue Mountain developed) destroys the publics trust in the planning process in Bracknell? Would the council and planning department expect residents to be able to trust any future commitments or statements it makes regarding planning in Bracknell in the future?

J Wilmott (ID1309) The council has already contravened a prior commitment not to build on the golf course and to the commitment not to build on BIN5 and BIN6 would place the Councils concerned and members into further disrepute.

J Clark (ID976) Blue Mountain planning application left the sites (BIN5 and BIN6) out of the plans. Suspicious that this was the plan by Luff Developments and the Council all along.

Harvey (ID458), E. Harvey (ID472)

Wish the Council would make a decision which is representative of the community – not one that benefits developers as with the overturning of Blue Mountains protected status.

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R. Glover (ID475) If proceed with development on these sites there is a real possibility of legal action

S Runham (ID495), S Butcher (ID982)

If the settlement boundary includes BIN6 it will be difficult for the Council to protect the safety / lifestyle of its residents in adjacent to Bin 6.

Higgins (ID505) The Council rejected the development of Foxley Oaks as it would do significant harm to the landscape and the proposed school / medical centre were not of sufficient value to offset this harm. SALP Policy CP1 seeks to take a positive approach to sustainable development in line with the NPPF. Foxley Oaks development was in conflict with this policy. Practically all of the objections for Foxley Oaks can be applied to all of the proposed sites in Binfield and the Council must take the site out of the Local Plan. Expect the Council to make comment as to why the objections used for Foxley Oaks are not relevant to Bin6.

Drew (ID509) How would developers explain the Sway school backing onto family homes?

V Baker (ID514) Sites do not fit within policy framework and negative impacts outweigh benefits.

A Glover (ID550), Large number of people will threaten close community A Osborn (ID555) Will not continue to invest in property and business if character and

rural setting is eroded by the Council. K Baylis (ID568), House will be devalued and new ones will be buy to lets. A and C Whitney (ID610), House prices will decrease C and L Jacobs (ID757) House prices will decrease due to loss of outlook G Ramsey (ID866) Price of new houses will be out of reach of local young people Burrowes and Henry (ID761) Concerned as paid a premium to live Binfield S Carter (ID1222), D Carter

(ID1223) Moved to Binfield as it was a peaceful and attractive area with lots of open space, yet this is being systematically eroded by the Borough’s development plans.

T Glover (ID620) Many of the houses on Emmets Park have had access to Bin6 through back gardens. Since these gates have existed and been in use for over two decades can claim a public right of way through the field.

R. Glover (ID475) Various residents have rights of way over BIN6. S Clark (ID655) Sites (BIN5 and BIN6) are Grade 3 agricultural land. Further

inspection needed to see if it is Grade 3a, land that is ‘best and most versatile’ and subject to NPPF and Guidance. (Extracts from NPPF).

Searle (ID160) Other sites more suitable (such as Coppid Beech Hill area which has better accessibility, new railway at Amen Corner, Jennets Park with park and ride should be priority sites).

C and L Jacobs (ID757) Understandably this has created suspicion (assurances that BIN5 and BIN6 would be open space / SANG) that it may have been a deliberate move of Luff and was part of their overall development plan from the beginning. Despite our attempt to find out what was happening with both sites over the last 13 months, details have been made very ambiguous and difficult to decipher. We feel deceived and let down by the Council.

J Clark (ID976) What is the relationship between Bracknell Forest Council and Luff Developments? Sites (BIN5 and BIN6) were originally promised as

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SANG only to be removed from the final planning application. Also Luff Developments have bought a house just next to BIN6. How can they be so sure that a planning application on this field will be approved? Have the Council given them some sort of reassurance? Removing BIN5 and BIN6 from the Local Plan will send a strong signal that the Council are operating ‘above board’ and not colluding with developers.

J Maloney (ID1358) Soil type which is problematic for development in a previous survey for possible allocated sites in Binfield. Disturbing the clay soil could pose a subsidence risk for the surrounding properties, as well as creating drainage issues.


Boyer on behalf of Luff In June 2016, Luff gained planning permission for “up to 400 Developments (ID1324) additional dwellings, a community facility, sports provision and open

space and full consent was gained for an all through school (Learning Village), approximately 13 hectares of Suitable Alternative Natural Greenspace (SANG), vehicular accesses from Temple Way, a spine road (known as Avenue A) through the development and a school drop off/SANG car park.”

Following the grant of planning permission Luff transferred the “Learning Village” land to BFC, the area with outline planning permission for housing SANG to Bloor Homes and Linden Homes.

Luff have retained the remainder of the site (Land West of Wood Lane) as well as the excess SANG capacity (over 4 hectares of SANG land). This excess capacity can be utilised for mitigation on land owned by Luff. Luff own two sites adjacent to the Blue Mountain site; known as Land south of Forest Road and east of Cheney Close (BIN5) and Land south of Emmets Park and east of Cressex Close (BIN6).

Bin6 is accessed from within the Emmets Park residential area. There is an existing gate leading into the site from Emmets Park. A group TPO covers the trees located adjacent to the existing gate. There are trees located around the site boundary. Highest point in the south western corner with a drop of approximately 8 metres between the southern and northern boundaries. The lowest point is the north eastern corner of the site, approximately 20m lower than the highest point of the site.

The site is within Flood Zone 1. There are no statutory or non-statutory nature conservation designations on the site. Binfield Hall Local Wildlife Site is located to the immediate south of the site. This is an area of Oak and Beech woodland.

There is an area of Ancient Woodland within this woodland, which is located approximately 15m from the southern site boundary at its nearest point. Development would therefore be more than 15m from

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Ancient Woodland, in line with Natural England’s guidance.

BIN5 and BIN6 both formed part of the original Blue Mountain allocation in Policy SA7 of the Site Allocations Local Plan (2013). (extract from Policy SA7).

The principle of development on BIN5 and BIN6 has therefore already been established. However, the Blue Mountain planning permission did not include BIN5 and BIN6 within the red line.

The full quantum of the 400 dwellings allocated by SALP Policy SA7 were shown within the red line area and Indicative Masterplan of the hybrid planning permission (ref. 16/00020/OUT). Therefore, whilst the principle of development is considered acceptable the amount of development appropriate for BIN5 and BIN6 needs to be established by the new Local Plan.

Boyer estimated a capacity for BIN5 of 42 dwellings and for BIN6 of 40 dwellings, both at an approximate density of 25 dwellings per hectare. In November 2016, the results of the Council’s initial assessments were released as part of the Strategic Housing and Economic Land Availability Assessment (SHELAA). The SHELAA assessments estimated the capacity of BIN5 as 50 dwellings and BIN6 as 42 dwellings. Boyer supported these estimated capacities.

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Responses to Section: 6.2. Residential/mixed use development/Policy LP3. Site BIN11 – Popes Farm, Murrell Hill Farm


Site BIN11 – Popes Farm, Murrell Hill Farm





Binfield Parish Council (ID254) The site is close to Popes Manor, its forecourt and garden walls (all grade II listed). Additional traffic from the new development along Murrell Hill Lane will seriously affect the setting of these heritage assets.

Binfield Parish Council (ID254) Believes that there are more than twenty trees with TPOs on the site. The trees add to the rural feel, as do all the trees along Murrell Hill Lane.

Binfield Parish Council (ID254) Bracknell Forest Council advertises its pride in the magnificent tree population within its Borough, many of which are in Binfield. Trees in Binfield are irreplaceable and are part of the local character and do not wish to see its local character or any trees of such standing, destroyed.


Binfield Parish Council (ID254) Murrell Hill Lane is rural and quiet, not designed for the proposed traffic to and from the development. It is part of a Ramblers Route and is likely to be used by recreational walkers.

Reference is made to the reasons for refusal in the Foxley Oaks appeal decision (Appeal Ref: APP/R0335/W/17/3177088).

Binfield Parish Council (ID254) Access to this site should be from the Amen Corner North development with all vehicle movements using the upgraded traffic light access to the London Road and not from Murrell Hill Lane. If necessary, a compulsory purchase order should be used to purchase any ransom strip that prevents this access and to protect the setting of Popes Manor.

Binfield Parish Council (ID254) London Road is extremely busy and additional traffic from Murrell Hill Lane will add to the problems. The junction with Murrell Hill Lane and Forest Road should be upgraded to only allow traffic to turn left from Murrell Hill Lane, to reduce the very high chance of accidents arising from traffic cutting across London Road.

Binfield Parish Council (ID254) Unfortunate that outline planning permission has been granted for this site for a net increase of 52 dwellings with access onto Murrell Hill Lane.




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Responses to Section: 6.2. Residential/mixed use development/Policy LP3. Site BIN11 – Popes Farm, Murrell Hill Farm



None received.


None received.

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Responses to Section: 6.2. Residential/mixed use development/Policy LP3. Site BRA6 – Bracknell and Wokingham College, Wick Hill, Sandy Lane


Site BRA6 – Bracknell and Wokingham College, Wick Hill, Sandy Lane







None received.


Turley on behalf of Bloor Homes Ltd (ID1435)

Note there is an application for 61 units pending consideration (17/00482/FUL), with concerns raised in relation to highways, drainage, arboriculture and design. Whilst this previously developed site is likely to secure permission in the future, do not consider completions will occur in 2020/21 as set out in the trajectory (Appendix 1 of the Draft Plan).

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Responses to Section: 6.2. Residential/mixed use development/Policy LP3. Site BRA7 – Town Square, The Ring


Site BRA7 – Town Square, The Ring





Wastewater network capacity is unlikely to support expected demand from the site. Likely to need strategic drainage infrastructure ensuring sufficient capacity is brought forward ahead of the development. Where wastewater network capacity is a constraint, developers to liaise with TWUL and provide a detailed drainage strategy with planning application, informing what infrastructure is required, where, when and how it will be delivered.



The town Centre Library and adjacent buildings which is an eyesore. Move the Library onto another site and use that land for apartments. Not enough affordable housing for young people without transport.


Turley on behalf of Bloor Conflicting information regarding the capacity of the site. The Homes Ltd (ID1435) SHELAA suggests 120 dwellings and 11,600 sqm of employment

floor space could be achieved on 0.8 hectares of developable land (of 1.16 ha gross). This density of development far exceeds that applied in the SHELAA methodology, which assumes 70 dph to be acceptable for such locations. The Draft Plan indicates a higher capacity of 200 units.

The site is currently occupied by a number of public sector organisations. The potential for redevelopment is therefore subject to expiry or cancellation of tenancies. Also noted that no development is involved at present.

The Appendix 1 trajectory suggests completions in 2030/31, however do not consider the site to be available or developable in light of the above.

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Responses to Section: 6.2. Residential/mixed use development/Policy LP3. Site BRA13 – Coopers Hill Youth and Community Centre, Crowthorne Road North


Site BRA13 – Coopers Hill Youth and Community Centre, Crowthorne Road North







CHARACTER

None received.


None received.


None received.

TRANSPORT

None received.

INFRASTRUCTURE

Bracknell Forest Society (ID163)

Bracknell Forest Local Plan Vision (3.1) states important community facilities will be protected. Coopers Hill is the only central community hall in Bracknell. If the site is redeveloped, a community hall should be included.

Wallen (ID844, 846), Bagshaw (ID1303)

Loss of community centre, where will a similar facility be provided?

OTHER MATTERS

None received.



Policy LP3 suggests a capacity of 69 dwellings, whereas the SHELAA suggests 111 dwellings and 5,300sqm of employment. The capacity of the site is ambiguous which undermines the reliability of the Plan.

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Responses to Section: 6.2. Residential/mixed use development/Policy LP3. Site SAND5 – Land east of Wokingham Road, and south of Dukes Ride (Derby Field)


Site SAND5 – Land east of Wokingham Road, and south of Dukes Ride (Derby Field)




Crowthorne Parish Council (ID399)

Site at Derby Field has limited road improvements indicated in the plan.


Wastewater treatment works unlikely to support expected demand from the site. Likely to need significant infrastructure upgrades, ensuring sufficient treatment capacity is available to serve this development. TWUL welcomes opportunity to work with BFC and developer to understand and plan for sewage treatment infrastructure for this development. Should not under estimate time for infrastructure delivery, e.g. 18 months to 3 years to design and build Sewage Treatment Works upgrade. Can be up to 10 years to implement new technologies, construct major treatment works extension or new treatment works. Wastewater network capacity may not support expected demand from the site. May need local upgrades to existing drainage infrastructure ensuring sufficient capacity is brought forwarding ahead of the development. Where wastewater network capacity is a potential constraint, developers to liaise with TWUL to determine if a detailed drainage strategy (informing what infrastructure is required, where, when and how it will be delivered) is required, to accompany the site’s planning application.


Allocation of the site not supported.

Whilst it is within the Sandhurst boundary, it represents an extension to the settlement of Crowthorne. Other sites adjoining this site have been rejected in the past of the basis of coalescence of settlements of Crowthorne and Sandhurst. The proposed change to the settlement boundary would be contrary to policy LP12 in the draft BFLP, and CS9 of the Core Strategy.

Lack of evidence to support comments in the sustainability appraisal such as it would not affect surrounding sites. Coalescence of settlements has not been considered in detail in the sustainability appraisal. (Also summarised in evidence base section relating to sustainability appraisal).



None received.

CHARACTER

Park Weir (ID126) Overdevelopment, given existing development on Dukes Ride.

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None received.


None received.

TRANSPORT

Park Weir (ID126) Existing traffic problems in rush hour, access to/from the site will add to traffic problems.

Crowthorne Village Action Group (ID567), Doran (ID603)

Comments relate to Derby Field. Fig 9 and Table 17, page 226. Development of the site represents an opportunity to remedy insufficient parking at Crowthorne station, and lack of public transport connection from the station to Crowthorne Village. It would also be good to have an off-road turning space where buses can turn and load without impeding traffic on Dukes Ride – these should be included in the Plan.

INFRASTRUCTURE

Park Weir (ID126) Existing facilities (schools, doctors, roads) will be over stretched (taken together with other developments: TRL, Broadmoor, Pinewood).

OTHER MATTERS

Crowthorne Village Action Group (ID567), Doran (ID603)

It is noted that this site would require an extension to the settlement boundary. Currently this field is within Sandhurst Parish. Since residents will be accessing facilities in Crowthorne Village, there should be an extension/alteration of Crowthorne Parish boundary to encompass this new development.

(Also see comments on appendices).

Woolf Bond on behalf of Hodson Developments (ID916-922), JPP Land and Neal (ID895), Flavia Estates and JPP Land (ID902, 903), Flavia Estates (ID915), JPP Land (ID 912), Warfield Park (ID1290)

Object to the draft allocation due to loss of open space contrary to the NPPF. There is no assessment of its value, or that of Wellington College, as open space in the Play, Open Space and Sports Study for Bracknell Forest (2016-2036) (August 2017), there is no justification for its redevelopment.


The proposal would result in the loss of a playing field which is not supported by evidence.

The site is also within a strategic gap between Crowthorne and Sandhurst (Housing Background Paper, page 185).

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Therefore, the site is not considered developable.

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Responses to Section: 6.2. Residential/mixed use development/Policy LP3. Site WAR9 – Land north of Herschel Grange


Site WAR9 – Land north of Herschel Grange






Warfield Parish Council (ID670) Opposes allocation of WAR9.



Warfield Village Action Group Site is located outside of a defined settlement, and is a greenfield (ID5), Stock (ID972, 973), site. Developing the site would set precedence for further Mauler (ID1608) development to the north of Warfield Street and for other sites in the

countryside. Warfield Village Action Group (ID970)

Further erosion of the small area of remaining countryside to the north of Warfield Street, the preservation of which has always been the Council's priority to uphold, is surely unforgivable and would breach new, current and former Council policies. BFBC policy has always been to maintain a gap of a field’s width between settlement and green belt, which is ‘the important green space function’ recognised in the Site Allocation Proformas for both sites WAR9 and WAR10, but this is yet another policy being eroded unnecessarily.

Warfield Street village is unique within the Bracknell Forest Borough and in the wider area – in terms of its rural village aspect with countryside, stables and farms, horse riding along Warfield Street and adjoining lanes, complete absence of street lighting, etc.

Warfield Village Action Group The claim made in the Council’s Basis of Allocation for each of the (ID970), Stock (ID972, 973) sites WAR9 and WAR10 is that ‘Although it is a greenfield site, the

proposal would represent the rounding off of the settlement’ which is clearly not true, as recognized in the Landscape Sensitivity Appraisal for WAR9, where it is admitted that the site will indeed ‘extend the built form a little further north into countryside than the current settlement edge’. Indeed, to redraw the settlement boundary to include countryside sites WAR9 and an expansion of WAR10 is clearly an attempt by the Council to justify (and mask) what is in fact an intrusive and invasive bulge into countryside.

Bateman (ID526) The Landscape Sensitivity Appraisal states that “Development of WAR10 would result in a greater impact than development on WAR9. The combined impact of developing both sites would be greater than developing WAR9 alone.” Therefore, the inclusion of development of WAR9 and WAR10 are not justifiable.

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O’Regan (ID541) Inconsistent approach regarding draft Warfield Neighbourhood Plan:

Local gaps given as a reason for non-inclusion of sites WAR18 and WAR19, however WAR9 and WAR10 are included.

Draft Warfield Neighbourhood Plan Paragraph 5.12 states that “over-development through cul-de-sac plots on the edge of settlements is no more welcomed by the community than building on the Green Belt”.

Stock (ID972, 973) Site is inconsistent with Warfield Neighbourhood Plan which recognises the importance of maintaining the ‘countryside gap’ between the defined settlement and greenbelt land.

Warfield Village Action Group (ID970), Stock (ID972, 973)

Neither WAR9 nor WAR10 are as contained as would appear from the Housing Background Paper, since trees and hedgerows in both WAR9 and WAR10 are predominantly deciduous (see photos).

Warfield Village Action Group The Landscape Sensitivity Appraisal for WAR9 states that the site is (ID970), Stock (ID972, 973) ‘visually enclosed’, though in fact it is very open and entirely visible

from Gibbins Lane country public footpath (see photo), so any development on the site would utterly destroy the surrounding countryside environment as well as the experience of Warfield Street village residents, visitors and walkers.

The report recognises that 'Development may harm these through alteration of local historic landscape character...'

Harm is alluded to in the Historic Environment Assessment to the potential prehistoric, Roman, medieval and post-medieval landscape significance of both sites and their external hedgerows.


'Recognises the intrinsic character and beauty of the countryside' (NPPF para. 17.5) is not the reality for WAR9 and WAR10.

Warfield Village Action Group The development of the site would result in indefensible boundaries; (ID970), Stock (ID972, 973) adjacent sites could then be developed in the interests of ‘rounding

off’ the settlement, completely altering the important setting of the rural northern boundary of Warfield Street as described recently by the LPA in their own evidence base and relied upon at recent appeals to defend the Council’s position.

Thompson (ID971) Need to preserve the countryside to the north of Warfield Street to maintain a balance with the more urbanised areas to the south.

Jennings (ID1174) Site does not comply with LP11 Protection of Countryside.

CHARACTER


Site is out of character with existing linear form of village/will impact upon the surrounding countryside and semi-rural character.

Warfield Village Action Group Warfield Street village is unique within the Bracknell Forest Borough (ID970), Stock (ID972, 973) and in the wider area – in terms of a significant number of character

buildings and heritage assets. Having designated Warfield Street as an Area of Character, the Council now seems set on undermining that character. Indeed, the Character Area of Warfield Street abuts directly the south-eastern boundary of WAR10, so to further develop

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this site will cause more harm to the character of this unique Character Area.

Warfield Village Action Group Allocation would contravene the Character Area Assessment. (ID970), Stock (ID972, 973)

Warfield Street Character Area Supplementary Planning Document� (adopted 2012) which acknowledges that the settlement is characterised by the linear form of development and that it is broken by a small number of cul-de-sac developments consisting of up to 10 dwellings (including Newhurst Gardens and Toogood Place). It aims to keep development south of Warfield Street, hence preserving the northern edge of Warfield Street settlement. It aims to retain the rural character of Warfield Street itself, hence access to the development south of Warfield Street will be off the larger Harvest Ride. The rejection by BFBC of recent planning applications for development of potential sites along Warfield Street, including land opposite Gibbins Lane, and Pear Tree and Lane End Cottages, also supports this planning policy.

Langdon (ID233), Taylor (ID272), Risius (ID471), Vassor (ID477), Wing (ID479), Ridgway (ID482), Bateman (ID526), Headland (ID591), Cooke (ID474), Reid (ID653), Hill (ID932), Warfield Village Action Group (ID970), Thompson (ID971), Stock (ID972, 973), Worcester (ID1280), Atack (ID1300), McLeod (ID1314)

Warfield will be harmed by the urbanisation and additional houses. Double the size of Warfield, impact quality of life, loss of amenity, noise. Character of this semi-rural street will change.

Morgan (ID302) Warfield Street is a haven away from busy Bracknell. Langley (ID308), Vassor Warfield has already seen 2,200 homes to the south and 50 houses (ID477), Chamberlain (ID484), at WAR10 to the north. Warfield has accepted its share of Headland (ID591), Blundell development, any further will destroy the semi-rural character of the (ID614), Reid (ID653), Fox settlement and area as a whole – something the Council said they (ID929), Warfield Village Action would preserve and protect. The plan urbanises a semirural area. Group (ID970), Thompson (ID971), Stock (ID972, 973), McLeod (ID1314) Stock (ID972, 973), Worcester (ID1280)

Concerns over the effect of increased traffic on the setting of Warfield Street. Including, traffic calming measures, pedestrian crossing etc proposed as part of planning application on site WAR10 are out of character with village character. Risk of further urbanisation through traffic lights or street lighting which would be out of character and contravene the village Dark Sky Policy.


Draft Warfield Neighbourhood Plan Housing Paragraph 4.4 raises concerns, “… but also about the impact on the character and culture

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of the villages and on parking requirements, which is a recurring theme.”

Fox (ID929) The development of 2,200 homes in Warfield is subject to various restrictions: offering ‘protection’ to the recognised village or ‘Character Areas’ of ‘Warfield Street’. One such restriction is that the development should be planned so there will be NO access from or onto Warfield Street. However WAR9 and WAR10 access via Warfield Street – on these grounds they should be removed from the plan.

Stock (ID972, 973) Other planning applications for sites with access to Warfield Street (e.g. opposite Gibbins Lane) have been rejected as they would contravene the Warfield Strategic Development Plan which aims to retain the character of Warfield Street. Maize Lane and Old Priory Lane are planned to be closed at the Warfield Street end for this reason.

Cooke (ID474) Not against new developments per se, developments such as that by Berkley Homes on Harvest Ride is exactly how it should be done, however, small developments such as these proposed at the back of Warfield Street that eat away at the character of village life are just plain wrong on so many levels.

Bateman (ID526) Seek to uphold the NPPF policy Para 17.5 and ‘Recognise the intrinsic character and beauty of the countryside’ and make provision for other more suitable sites that would cause less harm.


If the 96 houses proposed in the Draft BFLP for WAR10 were allowed - even without WAR9 with a further 33 houses - this would DOUBLE the existing size of Warfield Street village, and DOUBLE the traffic generated! 96 houses is also DOUBLE the 50 houses approved by the Planning Inspector at the Appeal which is a very significant increase and would not be appropriate or justifiable.


The proposed housing density of 30 dph currently applied to both WAR9 and WAR10 in the Draft BFLP, in order to accommodate the proposed large numbers of houses (96 and 33 respectively), would be completely out of character with the Newhurst Gardens cul-de-sac, as well as the entire surrounding village of Warfield Street, which is characterised by well spaced out, varied, character houses, bungalows and cottages and character heritage sites (see photos).

Stock (ID972, 973) Site allocation is inconsistent with previous planning applications. Expansion of the existing cul-de-sac of ten houses is disproportionate. An appeal on Tilehurst Land, Binfield was rejected based on the disproportionate size and nature of the proposed development (72 new dwellings vs the existing 42 dwellings) being unreasonable and out of character.

Collings (ID1089) Allocation of site opposes Policy LP18 (Design) – ensure that new development … respects local heritage and patterns of development.

HOUSING

Morgan (ID302), Ridgway (ID482), Chamberlain (ID484),

Enough houses have been built in this area, sites could and should be found elsewhere in Bracknell. This is overdevelopment.

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Richmond (ID580), Mauler (ID930), Hill (ID932), Atack (ID1300), McLeod (ID1314) Langley (ID308), Vassor The local plan contains more housing than needed to provide a 5 (ID477), Bateman (ID526), O’Regan (ID541), Blundell (ID614), Worcester (ID1280), Atack (ID1300)

year housing supply; therefore WAR9 does not need to be allocated.

Wing (ID479) Site between Warfield Street and Harvest Ride still not developed many years after given permission, indicating more development is not needed.

Bateman (ID526), O’Regan Inconsistency in site selection process relative to other sites along (ID541), Warfield Village Action Warfield Street/Forest Road relative to WAR9 and WAR10: five Group (ID970), Stock (ID972, other sites along the Warfield Street / Forest Road ‘divide’ where the 973) road forms a distinct physical boundary to further development in

North Bracknell; four other sites are excluded because they protrude into the countryside. For example, the Housing Background Paper rejects WAR24 on the basis that ‘Generally, it has a poor relationship with the existing settlement form, protruding into the countryside to the north. Forest Road forms a strong physical boundary to the settlement” and also WAR 6 is rejected because ‘the defined settlement boundary is on the opposite side of Forest Road. However, the latter forms a strong physical boundary to the settlement.” WAR9 and WAR10 also protrude into the countryside in the same manner.

Bateman (ID526), O’Regan Concerns over the connection between WAR9 and WAR10. The (ID541), Greenslade (ID1298) Housing Background Paper states that WAR9 and WAR10 must be

“considered together”. Is the intention to develop these are one housing estate? (See further comments under transport)

Warfield Village Action Group Not justifiable and not necessary, especially since there are over 70 (ID970), Stock (ID972, 973) other potential 'omitted' SHELAA sites to consider, including sites

within settlement and Previously Developed Land (PDL) sites, as well as further ‘windfall’ sites, many of which are also PDL so should automatically be 'preferred' to small greenfield sites like WAR9/WAR10. Together with the fact that there is already a significant buffer and over-allocation of housing land supply built into the Draft BFLP.

Stock (ID972, 973) There are thousands of new build flats/apartments coming onto the market; a high number of conversions from office buildings to residential; and other brownfield sites and empty office blocks still available for further development.

Warfield Village Action Group There are PDL sites eg Syngenta and 'windfall' sites, which should (ID970), Stock (ID972, 973) take preference over small, ad-hoc countryside sites like

WAR9/WAR10, especially when development of the latter also contravenes previous and new planning policies relating to preservation of countryside, heritage, unique character, wildlife, open space, etc as well as sustainability.


Warfield Street village is NOT the most appropriate area to choose to combat the current shortage in housing, since the need is for

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realistically affordable housing and NOT more housing in the more affluent areas.

Warfield Village Action Group Land owners and developers should be more strictly controlled (ID970), Stock (ID972, 973) before planning permission is granted to ensure that the dwellings

built are truly affordable and that prices are not artificially held at higher prices.

Collings (ID1089) Density is too and should be reduced, consistent with recent appeal decision on WAR10.


Vassor (ID477), Bateman (ID526), Blundell (ID614)

Uphold historic policy. Unique historic setting of Warfield Street, recognised in the Domesday Book and designated an ‘Area of Character’ by BFC should be preserved.

Warfield Village Action Group (ID970), Stock (ID972, 973), Vassor (ID477), Thompson (ID971), Worcester (ID1280)

Character and heritage setting of 10 Grade II Listed Buildings either abutting or close to the two sites.

Warfield Village Action Group (ID970), Stock (ID972, 973), Mauler (ID1608)

Warfield Street village is unique within the Bracknell Forest Borough and in the wider area – in terms of its historical interest with potential medieval archaeological sites, recognition in the Domesday Book and a significant number of character buildings and heritage assets.


Neither WAR9 nor WAR10 are as contained, and the abutting heritage assets are not as screened off, as would appear from the Housing Background Paper, since trees and hedgerows in both WAR9 and WAR10 are predominantly deciduous (see photos).

From these photos, it is clear that the character and settings of the Grade II Listed buildings - those abutting the site, as well as St Michael's Church to the north of the site (see photo), and others along Warfield Street (see photos) - will be significantly and unacceptably harmed.

The Council's Historic Environment Assessment of sites claims that development of WAR10 will have Low Effect on heritage settings due to the screening provided by a 'belt of trees forming the eastern site boundary'. The Heritage Assessment within the Site Allocation Proformas for WAR9 and WAR10 also confirms that 'several Grade II listed buildings are separated from the site by tree belts and recent development and are likely to have limited intervisibility’ and that ‘Overall, the level of potential effect is low with the site not likely to be viewed in combination with nearby heritage assets’ which is not the case, as seen from the photos, especially during winter months. Indeed, the original Historic Environment Assessment concludes that 'If development was to result in the loss of this feature (screening by trees), setting change (to Warfield House) is more likely with some level of harm as a consequence'. As is evident from the photos, the character and settings of Warfield House, North Farm, Old Farm, Lane End Cottage and Pear Tree Cottage, all Grade II Listed and directly abutting the WAR10 site, are

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in fact all at risk of exposure and intervisibility with development of the site.

Site visits made by authorities are invariably to the site entrance or gate only but, for sites like WAR10, in order to appreciate the proximity of, and harm to, the settings of the Grade II Listed buildings abutting the site, it is necessary to walk inside the site - see photos taken from within WAR10 which show very clearly the Grade II Listed buildings and the intrusion and damage to their respective settings.

4.6.8 of the Housing Background Paper claims that in the Draft BFLP, ‘regard has been paid to wider environmental considerations including…heritage assets…and the need to respect the character of the countryside and its settlement’, yet the existing proposals for WAR9 and WAR10 are clearly not consistent with this approach.


Inconsistency in how criteria are applied to different SHELAA sites; WAR9 and WAR10 are ‘preferred’ whilst WAR8 has been omitted. According to the Historic Environment Assessment, development of WAR8 was considered to have a High Effect on the heritage assets of neighbouring Newell Hall, also a Grade II Listed building, and refers to 'the development of immediately adjacent land which could undermine the ability to appreciate the nature and role of these heritage assets' and it states: 'Development is likely to lead to harm to the listed buildings' because of its adjacent position.

Warfield Village Action Group (ID970) , Stock (ID972, 973)

Potential damage to a further heritage asset also appears to have been overlooked in this evidence; Horseshoe House, a Grade II listed building situated right on the junction of Herschel Grange with Warfield Street (see photo), has not been acknowledged in the WAR9 Site Allocation Proforma, yet its character, setting and environment would undoubtedly be damaged by the doubling of traffic along Herschel Grange generated, if the proposed WAR9 development is to be included in the BFLP.

Warfield Village Action Group (ID970) , Stock (ID972, 973)

Alongside the SHELAA stating that there may be mineral deposits on site, the consultation response from Berkshire Archaeology states (in relation to the previous planning application) states that the site has potential to contain important archaeological remains. Two adjacent Listed Buildings (Pear Tree Cottage and Lane End Cottage) have both discovered archaeological remains.

Any application on the site should be refused unless credible and robust surveys have been undertaken, prior to determination, to establish the presence of such materials which may render the site unsuitable for development.


Langley (ID308), Vassor The plan damages biodiversity, TPOs and wildlife habitats for deer

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(ID477), Ridgway (ID482), (up to 25 deer at field edge), foxes, hedgehogs, stoats, weasels, Chamberlain (ID484), Blundell kites, bats, squirrels, pheasants, parakeets, geese, barn owls, little (ID614), Mauler (ID930), owls, sparrow hawks, sky lark, long tailed tits which nest in the Warfield Village Action Group Hawthorn and buzzards and Red Kite overhead. Reptiles include (ID970), Thompson (ID971), grass snakes, adders, frogs, toads and two species of newt. Some Stock (ID972, 973), Worcester protected species. (ID1280), McLeod (ID1314), Mauler (ID1608) Warfield Village Action Group (ID970), Stock (ID972, 973)

'Contributes to conserving the natural environment, preferring land of lesser environmental value' (NPPF para. 17.7) is not the case for WAR9 and WAR10.


Langley (ID308), Vassor Allocation of homes in an area without local shops, school within (ID477), Bateman (ID526), walking distance, hospitals, adequate transport or greenspace Warfield Village Action Group makes them unsustainable developments. (ID970), Thompson (ID971), Stock (ID972, 973) Warfield Village Action Group The River Cut and the Bull Brook pose a potential threat to nearby (ID970), Stock (ID972, 973) land, meaning that sites to the north or Warfield Street are potentially

at risk. There are often significant areas within WAR9 and WAR10 that are often waterlogged – concerns over suitability for development and consequences for existing residents. Site surveys measuring flood risk should be carried out by more than one independent company.


‘Focuses significant development in locations which are or can be made sustainable' (NPPF para. 17.11) is not the case for WAR9 and WAR10.


The focus and investment would be better spent on larger, more worthwhile, viable, sustainable, total community sites, rather than on small ad-hoc greenfield sites.

Warfield Village Action Group The site is Grade 3 (including Grade 3a) – the Best and Most (ID970) Stock (ID972, 973) Versatile Agricultural Land which national planning policies seek to

protect. NPPF Paragraph 112 provides that local planning authorities should “take into account the economic and other benefits of the best and most versatile agricultural land. Where significant development of agricultural land is demonstrated to be necessary, local planning authorities should seek to use areas of poor quality land in preference to that of high quality.”

Jennings (ID1174) Site is inconsistent with Policy LP1 (Sustainable Development Principles). Specifically, substantial new housing would not enhance and maintain local character (iii); would not protect and enhance the natural environment (iv); would not be located so as to reduce travel (viii); and would be totally reliant on private cars (ix).

TRANSPORT


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Draft Warfield Neighbourhood Plan Safety/Wellbeing paragraph 4.12 states that “the main concerns again relate to speeding traffic (in many locations but especially Harvest Ride, County Lane, around schools, and Warfield Street) and issues relating to poor parking.“

Draft Warfield Neighbourhood Plan Housing Paragraph 4.4 raises concerns, “most notably in respect of increased traffic and the impact on the local environment...”

Thompson (ID971) Inadequate site access. Blundell (ID614) Access assumed to be via Gibbons Lane or Herschel Grange which

are ridiculously small. Accidents waiting to happen. Wing (ID479), Atack (ID1300) Concerns over suitability of Herschel Grange for access, including:

• Poor road layout in Herschel Grange resulting in multiple point intersection in residential area.

• Cul-de-sac designed for a small number of houses • Herschel Grange is used by horses • Carriageway is not wide enough for two cars to pass • No footpaths • Young children play out the front of house • Speeding cars • Not suitable for construction traffic • Better to redevelop Hermitage Park to allow more logical

path to the new sites (as per previous plans for development).

Thompson (ID971), Cooke Concerns over junction of Herschel Grange and Warfield Street, (ID474) including:

• blind bends, poor visibility, parked cars, traffic etc • Junction was designed for 13 houses plus the mobile home

site – unsuitable for 83 (or 128) additional properties Headland (ID591) WAR9 has less accessibility than the restricted WAR10 site. O’Regan (ID541) If WAR9 and WAR10 combine, could WAR9 traffic exits via

Newhurst Gardens? If the sites combine, will access for WAR10 be via the more suitable Herschel Grange entrance with superior visibility, less parking on Warfield Street near the intersection and hence improved safety and traffic flow?

Worcester (ID1280) No detail available on how access will be constructed and made safe, and how this will impact current residents of Warfield Street.

Taylor (ID272), Morgan (ID302), Concerns over the volume of traffic on Warfield Street, the volume of Cooke (ID474), Headland traffic has increased and will get worse with new development e.g. (ID591), Mauler (ID930), Mauler increase in traffic in last six months/since Quelm Park, Woodhurst (ID930), Thompson (ID971), Park and the new school. Worcester (ID1280), Greenslade (ID1298), Atack (ID1300), McLeod (ID1314), Mauler (ID1608) McLeod (ID1314) Significant congestion at traffic lights at junction of Newell Green,

Warfield Street, forest Road and Osborne Lane. Air quality impacts. Wing (ID479), Ridgway (ID482), O’Regan (ID541), Blundell

Concerns over the safety of traffic on Warfield Street for road users and pedestrians. Reasons cited include poor visibility, blind bends,

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(ID614), Kent (ID742), Mauler (ID930), Warfield Village Action Group (ID970), Thompson (ID971), Thompson (ID971), Stock (ID972, 973), Worcester (ID1280), Atack (ID1300)

parked cars (lack of off-street parking), congestion at junctions, traffic coming out of junctions (Maize Lane, Newhurst Gardens, Herschel Grange and Toogood Place), no street lighting.

Reid (ID653) Exiting driveway is extremely dangerous as cars fly around the corner from Jogs Lane North – Forest Road/Bracknell Road junction (a busy junction with poor visibility).

Wing (ID479) Improved road infrastructure plan is required. Cooke (ID474) When the new Harvest Ride road was built a few years ago, part of

the reason was to alleviate the traffic on Warfield Street, which it has successfully achieved, however this retrograde step will simply push the situation back to an era when the Warfield Street residents became so frustrated with the traffic situation in 1997 that they effectively took the law into their own hands and blocked the road in protest. I presume the planning department do not want to drive the residents back to that situation.

Bateman (ID526) In the recent development of 2,200 houses South of Warfield Street, the council has retained traffic bollards on Maize Lane to prevent the outflow of traffic onto Warfield Street, thereby recognising that Warfield Street has a special character and that there is a need to regulate traffic flowing along it.

Risius (ID471) In the last two years several new roundabouts and traffic lights have been installed to ‘cope’ with the increased traffic which just add inconvenience and destroy the character of Warfield.

Reid (ID653) Pavements are inadequate, dangerous. Reid (ID653) Construction traffic will be unbearable. Mauler (ID930) There have been several accidents involving horse riders, cars and

motor cyclists coming out of Maize Lane. Warfield Village Action Group (ID970), Stock (ID972, 973)

The proposed open space would encourage visitors to the development and thus increase congestion and parking problems.

Greenslade (ID1298) Pot holes in roads.

INFRASTRUCTURE

Wing (ID479) No detail on layout provided, however more public recreational areas and open areas are needed as totally lacking in this area (hence target of 33 houses is far too high).

Warfield Village Action Group (ID970), Stock (ID972, 973), Greenslade (ID1298)

Water supply and waste water systems are already stretched and not able to cope with existing housing in Warfield Street village, without adding further houses. See photos.

Frequent low water pressure; recurrent and persistent burst pipes. Repairs frequently required at the Five Ways Junction, the end of Maize Lane and between Herschel Grange and the Plough and Harrow crossroads. Incidence of no water on 24/01/18.

Inadequate drainage systems in Warfield Street Village: significant stretches of water across the road occur after short burst of

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rain/snow; ditches overflow. Recurrent incidence over two months to March 2018 caused by ageing pipes, weight of traffic and weather conditions.

OTHER MATTERS

Warfield Village Action Group Comments made in representation refer to sites WAR9 and WAR10, (ID5), Stock (ID972, 973) please see comments summarised in relation to site WAR10:

Site not required to meet BFC’s housing supply, a more effective/efficient solution relates to land at Hayley Green, being promoted through the Warfield Neighbourhood Plan.

Headland (ID591) The supposed green belt to the north of Warfield Street is being urbanised.

Fox (ID929) Inconsistent approach regarding draft Warfield Neighbourhood Plan. The draft plan is due for submission in the next few weeks, inclusion of WAR9 and WAR10 would appear to be an attempt to railroad and undermine the neighbourhood plan process.

Over a three year period the Warfield Neighbourhood Plan Committee have carried out lengthy investigations and concluded WAR9 and WAR10 are not suitable for allocation. Recommendation is instead made for planned development at a larger site in Hayley, incorporating planned community infrastructure.

Warfield Village Action Group 'Seeks to improve health, social and cultural well-being' (NPPF para. (ID970), Stock (ID972, 973) 17.12) is not the case for WAR9 and WAR10. While the proposals

may provide a few more houses for other potential residences, it will significantly harm the ‘health, social and cultural well-being’ of existing Warfield Street village residents and visitors.


The proposed development is not aligned with and therefore contrary to the proposed Warfield Neighbourhood Plan.

Warfield Village Action Group Allocation of the site would contravene the Site Allocations (ID970), Stock (ID972, 973) Development Plan Document.

Page 75 of the Site Allocation Development Plan Document Preferred Option Background Paper states that this site sits within the North Warfield Area (which could deliver 111 units - although, as stated above, in the current SHELAA this has been increased to 115). Despite the large number of potential units available to the Council (who do not currently have a 5-year housing land supply) it was considered that the area contributes to the northern rural setting of Warfield Street. The document states that the “area is characterised by parkland, woodlands and hedges, and development on this site would erode the setting of the settlement.” “The scale of development would not relate to the existing settlement, would not create a more defensible boundary and would harm the setting of the area. 111 units in this location would harm the appearance of the countryside, the setting of the settlement and the surrounding landscape.” “The site is therefore not suitable for allocation of housing, or an edge of settlement site”. This evidence

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was also supported by the Landscape Capacity Study undertaken by Kirkham (2010) on behalf of the Council.

Warfield Village Action Group In various public inquiries for appeals, the Council has used its own (ID970), Stock (ID972, 973) evidence as stated above relating to the lack of 5-year supply.

Examples provided previously where independent Inspectors have dismissed appeals, stating that the lack of 5-year supply and need for available housing sites does not outweigh the demonstrable harm caused to the character and appearance of the area. Both appeal Inspectors agreed that just because paragraph 14 of the NPPF came into play, it did not mean that the housing supply policies of the development should be set aside, or that they should automatically attract insignificant weight. These decisions were made as recently as March 2016 and May 2016 (15/00452/OUT - 28 dwellings out-with the settlement boundary on land at Tilehurst Lane, Binfield and 14/01333/OUT - 88 dwellings out-with the settlement boundary on land west of Locks Ride, Winkfield Row, Bracknell.) It is inconceivable that the Council would consider permitting this planning application (or indeed consider allocating these sites) which would in effect override the decisions of these Inspectors and warrant the findings of their own evidence base unsound.

Jennings (ID1174) The justification for the development of War9 & War10 is questionable, yet they are projected to be completed in the period 2022/23 to 2026/27 (Figure 6 Land Supply). Development of these sites should be delayed until the need is more certain, i.e. towards the end of the plan period.


Hodson Developments (ID916-922)

Support the allocation of WAR9 and WAR10. If WAR10 is developed in accordance with the extant permission allowed on appeal, it will deliver 46 dwellings less than that envisaged in the emerging Local Plan (which is argued to provide a shortfall in housing). Support the revised settlement boundary. Further land is proposed to extend WAR9, which are available and within the control of the developer:

• The caravan park immediately to the west of WAR9; • 0.2ha of land immediately to the north of the caravan park

complex and east of the track beyond Gibbons Lane (there is existing development further to the north, Steeple View).

These would increase the capacity of WAR9 to 55 dwellings.

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Responses to Section: 6.2. Residential/mixed use development/Policy LP3. Site WAR10 – land north of Newhurst Gardens


Site WAR10 – land north of Newhurst Gardens





Wastewater treatment works is operating close to capacity. Recommend developer liaises with TWUL at earliest opportunity (according with NPPG) to determine magnitude of spare capacity and suitable connection point. Wastewater network capacity may not support expected demand from the site. May need local upgrades to existing drainage infrastructure ensuring sufficient capacity is brought forwarding ahead of the development. Where wastewater network capacity is a potential constraint, developers to liaise with TWUL to determine if a detailed drainage strategy (informing what infrastructure is required, where, when and how it will be delivered) is required, to accompany the site’s planning application.

Warfield Parish Council (ID670) Recognises WAR10 has been granted permission on appeal, but objection would have been extended to WAR10 and remains if there is an attempt to increase number of homes proposed for site.



Warfield Village Action Group Site is located outside of a defined settlement, and is an open (ID5), Linehan (ID749), Stock countryside greenfield site. Developing the site would set (ID972, 973), Mauler (ID1608) precedence for further development to the north of Warfield Street

and for other sites in the countryside. Warfield Village Action Group Further erosion of the small area of remaining countryside to the (ID970), Stock (ID972, 973) north of Warfield Street, the preservation of which has always been

the Council's priority to uphold, is surely unforgivable and would breach new, current and former Council policies. BFBC policy has always been to maintain a gap of a field’s width between settlement and green belt, which is ‘the important green space function’ recognised in the Site Allocation Proformas for both sites WAR9 and WAR10, but this is yet another policy being eroded unnecessarily.

Warfield Street village is unique within the Bracknell Forest Borough and in the wider area – in terms of its rural village aspect with countryside, stables and farms, horse riding along Warfield Street and adjoining lanes, complete absence of street lighting, etc.

Warfield Village Action Group The claim made in the Council’s Basis of Allocation for each of the (ID970), Stock (ID972, 973) sites WAR9 and WAR10 is that ‘Although it is a greenfield site, the

proposal would represent the rounding off of the settlement’ which is clearly not true, as recognized in the Landscape Sensitivity Appraisal for WAR9, where it is admitted that the site will indeed ‘extend the built form a little further north into countryside than the current settlement edge’. Indeed, to redraw the settlement boundary to include countryside sites WAR9 and an expansion of WAR10 is

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clearly an attempt by the Council to justify (and mask) what is in fact an intrusive and invasive bulge into countryside.

Bateman (ID526) The Landscape Sensitivity Appraisal states that “Development of WAR10 would result in a greater impact than development on WAR9. The combined impact of developing both sites would be greater than developing WAR9 alone.” Therefore, the inclusion of development of WAR9 and WAR10 are not justifiable.

Regarding WAR10, it states “development on the site on the scale proposed in the SHELAA would considerably increase the size of the village and could potentially have a poor relationship with the existing settlement form and its wider rural setting.” Its inclusion in the local plan is not defensible.


Local gaps given as a reason for non-inclusion of sites WAR18 and WAR19, however WAR9 and WAR10 are included.

Draft Warfield Neighbourhood Plan Paragraph 5.12 states that “over-development through cul-de-sac plots on the edge of settlements is no more welcomed by the community than building on the Green Belt”.


Harm is alluded to in the Historic Environment Assessment to the potential prehistoric, Roman, medieval and post-medieval landscape significance of both sites and their external hedgerows.


'Recognises the intrinsic character and beauty of the countryside' (NPPF para. 17.5) is not the reality for WAR9 and WAR10.


The development of the site would result in indefensible boundaries; adjacent sites could then be developed in the interests of ‘rounding off’ the settlement, completely altering the important setting of the rural northern boundary of Warfield Street as described recently by the LPA in their own evidence base and relied upon at recent appeals to defend the Council’s position.

Thompson (ID971) Need to preserve the countryside to the north of Warfield Street to maintain a balance with the more urbanised areas to the south.

Jennings (ID1174) Site does not comply with LP11 Protection of Countryside.

CHARACTER


The Council's Strategy has always been to protect the unique character of Warfield Street and rural land outside the settlement boundary to the north of Warfield Street.


Site is out of character with existing linear form of village/will impact upon the surrounding countryside and semi-rural character. Development will double the size of the existing village.


Warfield Street village is unique within the Bracknell Forest Borough and in the wider area – in terms of a significant number of character buildings and heritage assets. Having designated Warfield Street as an Area of Character, the Council now seems set on undermining that character. Indeed, the Character Area of Warfield Street abuts

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directly the south-eastern boundary of WAR10, so to further develop this site will cause more harm to the character of this unique Character Area.

Warfield Village Action Group Allocation would contravene the Character Area Assessment. (ID970), Stock (ID972, 973)

Warfield Street Character Area Supplementary Planning Document� (adopted 2012) which acknowledges that the settlement is characterised by the linear form of development and that it is broken by a small number of cul-de-sac developments consisting of up to 10 dwellings (including Newhurst Gardens and Toogood Place). It aims to keep development south of Warfield Street, hence preserving the northern edge of Warfield Street settlement. It aims to retain the rural character of Warfield Street itself, hence access to the development south of Warfield Street will be off the larger Harvest Ride. The rejection by BFBC of recent planning applications for development of potential sites along Warfield Street, including land opposite Gibbins Lane, and Pear Tree and Lane End Cottages, also supports this planning policy.


Draft Warfield Neighbourhood Plan Housing Paragraph 4.4 raises concerns, “… but also about the impact on the character and culture of the villages and on parking requirements, which is a recurring theme.”

Stock (ID972, 973) Site is inconsistent with Warfield Neighbourhood Plan which recognises the importance of maintaining the ‘countryside gap’ between the defined settlement and greenbelt land.

Taylor (ID272), Langdon Warfield will be harmed by the urbanisation and additional houses (ID233), O’Neal (ID257), Risius over the 50 already approved. Double the size of Warfield, impact (ID471), Vassor (ID477), quality of life, loss of amenity, noise. Character of this semi-rural Ridgway (ID482), Bateman street will change. (ID526), Headland (ID591), Blundell (ID614), Reid (ID653), Linehan (ID749), Hill (ID932), Warfield Village Action Group (ID970), Thompson (ID971), Stock (ID972, 973), Worcester (ID1280), McLeod (ID1314), McLeod (ID1314) Langley (ID308), Vassor Warfield has already seen 2,200 homes to the south and 50 houses (ID477), Chamberlain (ID484), at WAR10 to the north. Warfield has accepted its share of Headland (ID591), Blundell development, any further will destroy the semi-rural character of the (ID614), Blundell (ID614), Reid settlement and area as a whole – something the Council said they (ID653), Linehan (ID749), Fox would preserve and protect. The plan urbanises a semirural area. (ID929), Warfield Village Action Group (ID970), Thompson (ID971), Stock (ID972, 973), McLeod (ID1314) Stock (ID972, 973) Traffic calming measures, pedestrian crossing etc proposed as part

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of planning application on site WAR10 are out of character with village character. Risk of further urbanisation through traffic lights or street lighting which would be out of character and contravene the village Dark Sky Policy.

Fox (ID929) The development of 2,200 homes in Warfield is subject to various restrictions: offering ‘protection’ to the recognised village or ‘Character Areas’ of ‘Warfield Street’. One such restriction is that the development should be planned so there will be NO access from or onto Warfield Street. However WAR9 and WAR10 access via Warfield Street – on these grounds they should be removed from the plan.

Stock (ID972, 973) Other planning applications for sites with access to Warfield Street (e.g. opposite Gibbins Lane) have been rejected as they would contravene the Warfield Strategic Development Plan which aims to retain the character of Warfield Street. Maize Lane and Old Priory Lane are planned to be closed at the Warfield Street end for this reason.

Cooke (ID474) Not against new developments per se, developments such as that by Berkley Homes on Harvest Ride is exactly how it should be done, however, small developments such as these proposed at the back of Warfield Street that eat away at the character of village life are just plain wrong on so many levels.

Bateman (ID526) Seek to uphold the NPPF policy Para 17.5 and ‘Recognise the intrinsic character and beauty of the countryside’ and make provision for other more suitable sites that would cause less harm.

Warfield Village Action Group Concerns relating to the effect of increased traffic on the character of (ID5), Bateman (ID526), Taylor Warfield Street. Such issues could not be resolved through (ID272), Worcester (ID1280) urbanising traffic control measures as this would be out of character

with Warfield Street, which is without street lighting for this very reason.


Neither WAR9 nor WAR10 are as contained as would appear from the Housing Background Paper, since trees and hedgerows in both WAR9 and WAR10 are predominantly deciduous (see photos).

Warfield Village Action Group The proposed housing density of 30 dph currently applied to both (ID970), Stock (ID972, 973) WAR9 and WAR10 in the Draft BFLP, in order to accommodate the

proposed large numbers of houses (96 and 33 respectively), would be completely out of character with the Newhurst Gardens cul-de-sac, as well as the entire surrounding village of Warfield Street, which is characterised by well spaced out, varied, character houses, bungalows and cottages and character heritage sites (see photos).


Resolution of highway safety issues would result in urbanising aspects and100% harm to the unique village character that has been so highly regarded, preserved and loved!

Stock (ID972, 973) Site allocation is inconsistent with previous planning applications. Expansion of the existing cul-de-sac of ten houses is disproportionate. An appeal on Tilehurst Land, Binfield was rejected based on the disproportionate size and nature of the proposed development (72 new dwellings vs the existing 42 dwellings) being unreasonable and out of character.

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Collings (ID1089) Allocation of site opposes Policy LP18 (Design) – ensure that new development … respects local heritage and patterns of development.

Jennings (ID1174) Displaced equestrian facilities on Maze Lane could be relocated to WAR10 to help retain character of village Warfield Street.

(Also summarised under Policy LP15 Equestrian Uses)

HOUSING

O’Neal (ID257) House prices are dropping as there are so many houses on the market. Houses are taking months or years to see as there is no one looking or buying. People are not buying as it is extremely difficult to get a mortgage, not because there is a lack of houses.

Morgan (ID302), Ridgway Enough houses have been built in this area, sites could and should (ID482), Chamberlain (ID484), be found elsewhere in Bracknell. This is over development. Use the Richmond (ID580), Kent other much bigger sites in the draft planning document instead of (ID742), Mauler (ID930), Hill WAR10 to build the much needed houses in this borough. (ID932) Warfield Village Action Group The local plan contains more housing than needed to provide a 5 (ID5), Langley (ID308), Vassor year housing supply, therefore WAR10 does not need its allocation (ID477), Bateman (ID526), of houses increased above the 50 for which planning permission has O’Regan (ID541), Blundell been granted. (ID614), Stock (ID972, 973), Worcester (ID1280) Warfield Village Action Group (ID5), Stock (ID972, 973)

A better and more efficient and effective means of contributing to the necessary housing land supply will be deliverable through the Warfield Neighbourhood Plan (Hayley Green site).

Bateman (ID526), O’Regan Inconsistency in site selection process relative to other sites along (ID541), Warfield Village Action Warfield Street/Forest Road relative to WAR9 and WAR10: five Group (ID970), Stock (ID972, other sites along the Warfield Street / Forest Road ‘divide’ where the 973) road forms a distinct physical boundary to further development in

North Bracknell; four other sites are excluded because they protrude into the countryside. For example, the Housing Background Paper rejects WAR24 on the basis that ‘Generally, it has a poor relationship with the existing settlement form, protruding into the countryside to the north. Forest Road forms a strong physical boundary to the settlement” and also WAR 6 is rejected because ‘the defined settlement boundary is on the opposite side of Forest Road. However, the latter forms a strong physical boundary to the settlement.” WAR9 and WAR10 also protrude into the countryside in the same manner.

Bateman (ID526), O’Regan Concerns over the connection between WAR9 and WAR10. The (ID541), Greenslade (ID1298) Housing Background Paper states that WAR9 and WAR10 must be

“considered together”. Is the intention to develop these are one housing estate? (See further comments under transport)

Bateman (ID526), O’Regan (ID541)

WAR10 has a permitted development of ‘up to 50’ houses as per the planning inspector appeal on 16th January, that number should not be increased. 96 dwellings would result in loss of the proposed

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green areas around the edges of the site, impacting visual amenity to residents. The current developable area assessment allocates a negligible buffer to the properties at 5 and 6 Newhurst Gardens. Will BFBC increase the buffer with 5 and 6 Newhurst Gardens to be published in the Local Plan to at least equal the width of the widest buffer afforded to properties fronting Warfield Street?

O’Regan (ID541) Will BFC limit dwellings to the 50 for which planning permission was granted?

Richmond (ID580) No proper bus service to cater for people needing the affordable housing. They would have to run a car if they can afford to, to get to work in Bracknell or to get a train link to London. Property near the town centre is better for these people with a walkable transport system.

Warfield Village Action Group Not justifiable and not necessary, especially since there are over 70 (ID970), Stock (ID972, 973) other potential 'omitted' SHELAA sites to consider, including sites

within settlement and Previously Developed Land (PDL) sites, as well as further ‘windfall’ sites, many of which are also PDL so should automatically be 'preferred' to small greenfield sites like WAR9/WAR10. Together with the fact that there is already a significant buffer and over-allocation of housing land supply built into the Draft BFLP.

Stock (ID972, 973) There are thousands of new build flats/apartments coming onto the market; a high number of conversions from office buildings to residential; and other brownfield sites and empty office blocks still available for further development.

Warfield Village Action Group There are PDL sites eg Syngenta and 'windfall' sites, which should (ID970), Stock (ID972, 973) take preference over small, ad-hoc countryside sites like

WAR9/WAR10, especially when development of the latter also contravenes previous and new planning policies relating to preservation of countryside, heritage, unique character, wildlife, open space, etc as well as sustainability.

Warfield Village Action Group Warfield Street village is NOT the most appropriate area to choose (ID970), Stock (ID972, 973) to combat the current shortage in housing, since the need is for

realistically affordable housing and NOT more housing in the more affluent areas.

Warfield Village Action Group Land owners and developers should be more strictly controlled (ID970), Stock (ID972, 973) before planning permission is granted to ensure that the dwellings

built are truly affordable and that prices are not artificially held at higher prices.

Collings (ID1089) Density is too and should be reduced, consistent with recent appeal decision on the site where the planning inspector endorsed up to 50 dwellings as a density consistent with that in Newhurst Gardens (item 37 of his report).


Warfield Village Action Group Impact upon the setting and views of heritage assets (Directly (ID5), Stock (ID972, 973) bordering the site: Pear Tree Cottage, Lane End Cottage, Warfield

House, North Farm, Old Farm; and visible from the site: St Michael’s Church).

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Warfield Village Action Group (ID970), Stock (ID972, 973), Mauler (ID1608)

Warfield Street village is unique within the Bracknell Forest Borough and in the wider area – in terms of its historical interest with potential medieval archaeological sites, recognition in the Domesday Book and a significant number of character buildings and heritage assets.

Vassor (ID477), Thompson Ten heritage sites abutting or close to the two sites. (ID971), Warfield Village Action Group (ID970), Stock (ID972, 973), Worcester (ID1280), O’Neal (ID257) Doubling the planning permission for 50 homes to 90 will destroy the

historic community. Vassor (ID477), Bateman Uphold historic policy. Unique historic setting of Warfield Street, (ID526), Blundell (ID614), recognised in the Domesday Book and designated an ‘Area of Linehan (ID749) Character’ by BFC should be preserved. WAR10 falls within the

Character Area. Bateman (ID526) There are a number of heritage assets on Warfield Street and there

are inconsistencies in the application of criteria along the same street on different sites. The Historic Environment Assessment appears to suggest that any development of WAR8 would cause harm on the Grade II listed status of Newell Hall, by “the development of immediately adjacent land which could undermine the ability to appreciate the nature and role of these heritage assets.” However, that same policy has not been applied to the Grade II listed buildings that directly border the War 10 site which are unnamed where a level of ‘Low’ has been applied and refers to a visual screen of deciduous trees along the boundary – meaning that it will be visible during the winter months. This will affect Pear Tree Cottage and Warfield House and will result in harm to these assets.


Neither WAR9 nor WAR10 are as contained, and the abutting heritage assets are not as screened off, as would appear from the Housing Background Paper, since trees and hedgerows in both WAR9 and WAR10 are predominantly deciduous (see photos).

From these photos, it is clear that the character and settings of the Grade II Listed buildings - those abutting the site, as well as St Michael's Church to the north of the site (see photo), and others along Warfield Street (see photos) - will be significantly and unacceptably harmed.

The Council's Historic Environment Assessment of sites claims that development of WAR10 will have Low Effect on heritage settings due to the screening provided by a 'belt of trees forming the eastern site boundary'. The Heritage Assessment within the Site Allocation Proformas for WAR9 and WAR10 also confirms that 'several Grade II listed buildings are separated from the site by tree belts and recent development and are likely to have limited intervisibility’ and that ‘Overall, the level of potential effect is low with the site not likely to be viewed in combination with nearby heritage assets’ which is not the case, as seen from the photos, especially during winter months. Indeed, the original Historic Environment

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Assessment concludes that 'If development was to result in the loss of this feature (screening by trees), setting change (to Warfield House) is more likely with some level of harm as a consequence'. As is evident from the photos, the character and settings of Warfield House, North Farm, Old Farm, Lane End Cottage and Pear Tree Cottage, all Grade II Listed and directly abutting the WAR10 site, are in fact all at risk of exposure and intervisibility with development of the site.

Site visits made by authorities are invariably to the site entrance or gate only but, for sites like WAR10, in order to appreciate the proximity of, and harm to, the settings of the Grade II Listed buildings abutting the site, it is necessary to walk inside the site - see photos taken from within WAR10 which show very clearly the Grade II Listed buildings and the intrusion and damage to their respective settings.

4.6.8 of the Housing Background Paper claims that in the Draft BFLP, ‘regard has been paid to wider environmental considerations including…heritage assets…and the need to respect the character of the countryside and its settlement’, yet the existing proposals for WAR9 and WAR10 are clearly not consistent with this approach.

Warfield Village Action Group 4.4.7 of the Housing Background Paper recognises that within some (ID970), Stock (ID972, 973) sites, ‘development should be limited’ and development will need to

involve ‘discounting certain constrained areas within sites eg land that contributes to the setting of listed buildings…… trees, etc’. This strategy should certainly be applied to WAR10, yet the ‘developable’ area illustrated on the plan in the Site Allocation Proforma for this site almost fills the entire site area. Indeed, given that the accommodation of ‘up to 50’ houses for the WAR10 planning application covered over half of the entire site, it would be impossible to accommodate the 96 houses proposed in the Draft BFLP without using the entire site.

Warfield Village Action Group Inconsistencies and apparent inaccuracies in Assessment evidence (ID970), Stock (ID972, 973) include heritage maps of the area and of WAR10, which do not

appear to recognise that North Farm and Old Farm, which abut the WAR10 site, both lie within the curtilage of Warfield House and are therefore Grade II Listed so deserve the same level of protection over their heritage settings. The WAR10 map does not even extend far enough east to include neighbouring Warfield House and so fails to show that the curtilage boundary of Warfield House shares a common boundary with the WAR10 site for about 50% of the total site boundary, along its northern and eastern edges, let alone that the Grade II Listed buildings, North Farm and Old Farm within its curtilage directly abut, and are extremely close to, the WAR10 site (see photo).

Warfield Village Action Group Inconsistency in how criteria are applied to different SHELAA sites; (ID970), Stock (ID972, 973) WAR9 and WAR10 are ‘preferred’ whilst WAR8 has been omitted.

According to the Historic Environment Assessment, development of WAR8 was considered to have a High Effect on the heritage

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assets of neighbouring Newell Hall, also a Grade II Listed building, and refers to 'the development of immediately adjacent land which could undermine the ability to appreciate the nature and role of these heritage assets' and it states: 'Development is likely to lead to harm to the listed buildings' because of its adjacent position.

Stock (ID972, 973) Development would cause demonstrable harm to the landscape and setting of St Michael the Archangel Church, a listed building, and its open countryside views (currently no housing to be seen). (Photo of view from roof of the church is provided).


Langley (ID308), Vassor The plan damages biodiversity, TPOs and wildlife habitats for deer (ID477), Ridgway (ID482), (up to 25 deer at field edge), foxes, hedgehogs, stoats, weasels, Chamberlain (ID484), Blundell kites, bats, squirrels, pheasants, parakeets, geese, barn owls, little (ID614), Mauler (ID930), owls, sparrow hawks, sky lark, long tailed tits which nest in the Warfield Village Action Group Hawthorn and buzzards and Red Kite overhead. Reptiles include (ID970), Thompson (ID971), grass snakes, adders, frogs, toads and two species of newt. Some Stock (ID972, 973), Worcester protected species. (ID1280), McLeod (ID1314), Mauler (ID1608) Warfield Village Action Group The WAR10 Landscape Sensitivity Appraisal statement that ‘It is (ID970), Stock (ID972, 973) assumed that the trees on and around the site can be

accommodated within the open space provision included in the SHELAA proposal’ will simply not be possible with a higher number of housing than the 50 dwellings already approved.


'Contributes to conserving the natural environment, preferring land of lesser environmental value' (NPPF para. 17.7) is not the case for WAR9 and WAR10.


Warfield Village Action Group (ID5), Langley (ID308), Vassor (ID477), Bateman (ID526), Richmond (ID580), Linehan (ID749), Warfield Village Action Group (ID970), Thompson (ID971), Stock (ID972, 973)

Allocation of homes in an area without local shops, school within walking distance, hospitals, employment, adequate greenspace makes them unsustainable developments. The bus service is infrequent and does not run at all on Sundays.

Warfield Village Action Group The River Cut and the Bull Brook pose a potential threat to nearby (ID970), Stock (ID972, 973) land, meaning that sites to the north or Warfield Street are potentially

at risk. There are often significant areas within WAR9 and WAR10 that are often waterlogged – concerns over suitability for development and consequences for existing residents. Site surveys measuring flood risk should be carried out by more than one independent company.


‘Focuses significant development in locations which are or can be made sustainable' (NPPF para. 17.11) is not the case for WAR9 and

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WAR10. Warfield Village Action Group (ID970), Stock (ID972, 973)

The focus and investment would be better spent on larger, more worthwhile, viable, sustainable, total community sites, rather than on small ad-hoc greenfield sites.


The site is Grade 3 (including Grade 3a) – the Best and Most Versatile Agricultural Land which national planning policies seek to protect. NPPF Paragraph 112 provides that local planning authorities should “take into account the economic and other benefits of the best and most versatile agricultural land. Where significant development of agricultural land is demonstrated to be necessary, local planning authorities should seek to use areas of poor quality land in preference to that of high quality.”

Jennings (ID1174) Site is inconsistent with Policy LP1 (Sustainable Development Principles). Specifically, substantial new housing would not enhance and maintain local character (iii); would not protect and enhance the natural environment (iv); would not be located so as to reduce travel (viii); and would be totally reliant on private cars (ix).

Greenslade (ID1298) (Referring to the previous planning application on WAR10 which was refused) The 50 houses were seen as unsustainable – how has this changed in the last year?

Greenslade (ID1298) What facilities exist for children in the near vicinity?

TRANSPORT

Warfield Village Action Group (ID5), Vassor (ID477), O’Regan (ID541), Blundell (ID614), Stock (ID972, 973),

Insufficient and unsafe access on to the actual site. Access to the site has not been secured; it is not fully owned by the site owner hence road/footpath(s) cannot be accommodated.

Warfield Village Action Group (ID970), Stock (ID972, 973), Worcester (ID1280)

The access arrangements would impact upon existing properties in Newhurst Gardens.

Worcester (ID1280) No detail available on how access will be constructed and made safe, and how this will impact current residents of Warfield Street.

Linehan (ID749), O’Regan (ID541)

Foresee a build up of cars exiting Newhurst Gardens. Residents to other properties in Warfield often park in Newhurst Gardens, making the problem worse.

O’Regan (ID541) If WAR9 and WAR10 combine, could WAR9 traffic exits via Newhurst Gardens? Will revised matters planning considerations for WAR10 be put on hold until after consultation re the relationship of the sites including access? If the sites combine, will access for WAR10 be via the more suitable Herschel Grange entrance with superior visibility, less parking on Warfield Street near the intersection and hence improved safety and traffic flow?

Linehan (ID749) Build a new road to serve WAR9 and WAR10 and leave Newhurst Gardens alone. A house will be demolished for houses in WAR9, WAR10 could use the same route.

Cooke (ID474) Suspect WAR9 and WAR10 will be linked - the junction of Warfield

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Street and Herschel Grange is totally unsuitable for such an increase in traffic use. The junction was only designed to cater for the traffic from 13 houses plus the mobile home site. Neither the junction or Warfield Street is capable of coping with the additional traffic.

Warfield Village Action Group (ID5), Vassor (ID477), Chamberlain (ID484), Bateman (ID526), Blundell (ID614), Kent (ID742), Hill (ID932), Warfield Village Action Group (ID970), Thompson (ID971), Thompson (ID971), Stock (ID972, 973), Greenslade (ID1298)

Insufficient access and highway safety concerns relating to junction of Newhurst Gardens and Warfield Street: Significant highways safety implications onto Warfield Street due to the location of the access junction (Newhurst Gardens) on a severe blind bend (see photos, ID970) plus the existing hazards of parked vehicles, vehicles reversing from driveways onto the road, horses and unacceptably high and dangerous levels of traffic

Stock (ID972, 973) Other smaller planning applications for development with access onto Warfield Street have been rejected, one of the grounds being poor visibility e.g. Pear Tree/Lane End Cottage near to and on the same side as Newhurst Gardens.

Taylor (ID272), Morgan (ID302), Vassor (ID477), Bateman (ID526), Headland (ID591), Blundell (ID614), Kent (ID742), Mauler (ID930), Piercy (ID933), Warfield Village Action Group (ID970), Thompson (ID971), Stock (ID972, 973), Worcester (ID1280), McLeod (ID1314), Mauler (ID1608)

Concerns relating to the volume of traffic on Warfield Street, specifically:

• Traffic volumes have grown over the last 40 years from a quiet and basic throughfare. It was originally based on a lane.

• Warfield Street is subject to a large volume of traffic which will only get worse with the proposed development, along with the 2,200 homes to the south.

• Current congestion at junctions (e.g. at junction of Newell Green, Warfield Street, forest Road and Osborne Lane); air quality impacts.

• Traffic has increased since development of Quelm Park and Woodhurst Park plus the new school, it is very noticeable in the morning from 7:30am and anytime after 2:30pm, especially on Fridays.

• Traffic has increased since The Lexicon opened. • Warfield Street is used as a cut though.

Linehan (ID749), Vassor (ID477), Ridgway (ID482), Bateman (ID526), Headland (ID591), Blundell (ID614), Kent (ID742), Mauler (ID930), Hill (ID932), Piercy (ID933), Warfield Village Action Group (ID970), Thompson (ID971), Stock (ID972, 973), Worcester (ID1280), Greenslade (ID1298), McLeod (ID1314)

Concerns relating to the safety of traffic on Warfield Street, specifically:

• Additional traffic will make traffic even more hazardous than it is at present.

• Dangerous to reverse out of (small) driveways onto Warfield Street.

• Cars park on either side of the road (no off-street parking) and pavement (narrow width forces cars to park on the pavement)

• Horse riders (from two local stable; see photos, ID970), pedestrians (including those with pushchairs), elderly residents (including those on mobility scooters), cyclists are at danger from traffic. Fear of horse riders.

• Prams, the elderly and dog walkers have to walk in the road

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due to blocked pavements. • Warfield Street is a relatively narrow road unsuitable for high

volumes of traffic or large lorries etc. Making one end of Warfield Street very narrow (or something else) would help stop lorries using our street would be of great help.

• Blinds bends and traffic coming out of Maize Lane, Newhurst Gardens, Herschel Grange and Toogood Place.

• Speeding traffic (some at 70 mph). • Highway safety has not been considered or fully investigated

at this stage. • No street lighting. • High number of junctions, including large complex and

dangerous junctions at either end. • Frequent flooding along the length of the street, including

pavements. Resultant ice. Kent (ID742), Warfield Village Disagree with Transport assessment relating to appeal on WAR10 re Action Group (ID970), Stock safety of Newhurst Gardens junction (blind bends in both directions). (ID972, 973) Figures for extra journey times during peak time must be revisited,

especially in light of planning twice as many houses. Collings (ID1089) In the recent appeal, the Planning Inspector’s consideration of

increased traffic (item 22 of his report) is flawed in that they have no consideration of the impact of all development in the area.

Bateman (ID526), Chamberlain Serious accident at 16:30 on 11th March 2016 at the Newhurst (ID484), Vassor (ID477), Gardens junction involving a horse and rider and a vehicle. Near Lineham (ID749), Warfield miss with a pedestrian on another occasion; other near misses Village Action Group (ID970), between vehicles at this junction. Thompson (ID971), Stock (ID972, 973) Mauler (ID930) There have been several accidents involving horse riders, cars and

motor cyclists coming out of Maize Lane. O’Neal (ID257) The scheme will create a huge amount of traffic along a dangerous

road (assumed to refer to Warfield Street). Linehan (ID749) Warfield Street is used as a cut through to Maidenhead, there will be

much more traffic once Crossrail is open in December 2019. Reid (ID653) Exiting driveway is extremely dangerous as cars fly around the

corner from Jogs Lane North – Forest Road/Bracknell Road junction (a busy junction with poor visibility).

Risius (ID471) In the last two years several new roundabouts and traffic lights have been installed to ‘cope’ with the increased traffic which just add inconvenience and destroy the character of Warfield.

Cooke (ID474) When the new Harvest Ride road was built a few years ago, part of the reason was to alleviate the traffic on Warfield Street, which it has successfully achieved, however this retrograde step will simply push the situation back to an era when the Warfield Street residents became so frustrated with the traffic situation in 1997 that they effectively took the law into their own hands and blocked the road in protest. I presume the planning department do not want to drive the residents back to that situation.

Bateman (ID526) In the recent development of 2,200 houses South of Warfield Street, the council has retained traffic bollards on Maize Lane to prevent the

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outflow of traffic onto Warfield Street, thereby recognising that Warfield Street has a special character and that there is a need to regulate traffic flowing along it.

Richmond (ID580), Reid (ID653)

Pavements are inadequate, dangerous.

Reid (ID653) Construction traffic will be unbearable. O’Regan (ID541) Inconsistent approach regarding draft Warfield Neighbourhood Plan:

Draft Warfield Neighbourhood Plan Safety/Wellbeing paragraph 4.12 states that “the main concerns again relate to speeding traffic (in many locations but especially Harvest Ride, County Lane, around schools, and Warfield Street) and issues relating to poor parking.“

Draft Warfield Neighbourhood Plan Housing Paragraph 4.4 raises concerns, “most notably in respect of increased traffic and the impact on the local environment...”

Warfield Village Action Group (ID970), Stock (ID972, 973) Warfield Village Action Group (ID970), Stock (ID972, 973)

The proposed open space would encourage visitors to the development and thus increase congestion and parking problems.

Stock (ID972, 973) A pedestrian crossing across Warfield Street near to the Newhurst Gardens junction would be highly dangerous (blind bend, parked cars).

Greenslade (ID1298) Pot holes in roads.

INFRASTRUCTURE

Warfield Village Action Group (ID970), Stock (ID972, 973), Greenslade (ID1298)

Water supply and waste water systems are already stretched and not able to cope with existing housing in Warfield Street village, without adding further houses. See photos.

Frequent low water pressure; recurrent and persistent burst pipes. Repairs frequently required at the Five Ways Junction, the end of Maize Lane and between Herschel Grange and the Plough and Harrow crossroads. Incidence of no water on 24/01/18.

Inadequate drainage systems in Warfield Street Village: significant stretches of water across the road occur after short burst of rain/snow; ditches overflow. Recurrent incidence over two months to March 2018 caused by ageing pipes, weight of traffic and weather conditions.

OTHER MATTERS


Previous application (16/01004/OUT) has been refused, and considered at an appeal in January.


Site not required to meet BFC’s housing supply, a more effective/efficient solution relates to land at Hayley Green, being promoted through the Warfield Neighbourhood Plan


Site is not sustainable.

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O’Neal (ID257) The consultation is probably a sham, very sceptical that response will have any impact.

O’Neal (ID257) The level of development overall will build on all the green space, destroy wildlife and communities and create gridlock.

Blundell (ID614) Residents neighbouring WAR9 and WAR10 were not notified of the consultation, residents have not had time to respond as they would have liked to. Fundamentally unfair and unjust.

Linehan (ID749) How many times are BFC going to move the settlement boundary? Fox (ID929) Inconsistent approach regarding draft Warfield Neighbourhood Plan.

The draft plan is due for submission in the next few weeks, inclusion of WAR9 and WAR10 would appear to be an attempt to railroad and undermine the neighbourhood plan process.

Over a three year period the Warfield Neighbourhood Plan Committee have carried out lengthy investigations and concluded WAR9 and WAR10 are not suitable for allocation. Recommendation is instead made for planned development at a larger site in Hayley, incorporating planned community infrastructure.

Warfield Village Action Group 'Seeks to improve health, social and cultural well-being' (NPPF para. (ID970), Stock (ID972, 973) 17.12) is not the case for WAR9 and WAR10. While the proposals

may provide a few more houses for other potential residences, it will significantly harm the ‘health, social and cultural well-being’ of existing Warfield Street village residents and visitors.


The proposed development is not aligned with and therefore contrary to the proposed Warfield Neighbourhood Plan.

Warfield Village Action Group Allocation of the site would contravene the Site Allocations (ID970), Stock (ID972, 973) Development Plan Document.

Page 75 of the Site Allocation Development Plan Document Preferred Option Background Paper states that this site sits within the North Warfield Area (which could deliver 111 units - although, as stated above, in the current SHELAA this has been increased to 115). Despite the large number of potential units available to the Council (who do not currently have a 5-year housing land supply) it was considered that the area contributes to the northern rural setting of Warfield Street. The document states that the “area is characterised by parkland, woodlands and hedges, and development on this site would erode the setting of the settlement.” “The scale of development would not relate to the existing settlement, would not create a more defensible boundary and would harm the setting of the area. 111 units in this location would harm the appearance of the countryside, the setting of the settlement and the surrounding landscape.” “The site is therefore not suitable for allocation of housing, or an edge of settlement site”. This evidence was also supported by the Landscape Capacity Study undertaken by Kirkham (2010) on behalf of the Council.


In various public inquiries for appeals, the Council has used its own evidence as stated above relating to the lack of 5-year supply. Examples provided previously where independent Inspectors have

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dismissed appeals, stating that the lack of 5-year supply and need for available housing sites does not outweigh the demonstrable harm caused to the character and appearance of the area. Both appeal Inspectors agreed that just because paragraph 14 of the NPPF came into play, it did not mean that the housing supply policies of the development should be set aside, or that they should automatically attract insignificant weight. These decisions were made as recently as March 2016 and May 2016 (15/00452/OUT - 28 dwellings out-with the settlement boundary on land at Tilehurst Lane, Binfield and 14/01333/OUT - 88 dwellings out-with the settlement boundary on land west of Locks Ride, Winkfield Row, Bracknell.) It is inconceivable that the Council would consider permitting this planning application (or indeed consider allocating these sites) which would in effect override the decisions of these Inspectors and warrant the findings of their own evidence base unsound.

Jennings (ID1174) The justification for the development of War9 & War10 is questionable, yet they are projected to be completed in the period 2022/23 to 2026/27 (Figure 6 Land Supply). Development of these sites should be delayed until the need is more certain, i.e. towards the end of the plan period.

Worcester (ID1280) Concerns over the increase in number of dwellings from 50 allowed at appeal. Underhand and worrying extension; lack of confidence in information provided to residents.

Greenslade (ID1298) Why within one year the reasons for objection to the 50 houses proposed for WAR10 was accepted, has this now been completely reversed?

Greenslade (ID1298) WAR10 was outside the boundary of Warfield Village and not part of any development plan – how has this changed in the last year?

Greenslade (ID1298) Is the site classed as open country greenfield land?


Hodson Developments (ID916-922)

Support the allocation of WAR9 and WAR10. If WAR10 is developed in accordance with the extant permission allowed on appeal, it will deliver 46 dwellings less than that envisaged in the emerging Local Plan (which is argued to provide a shortfall in housing). Support the revised settlement boundary. Further land is proposed to extend WAR9 (refer to WAR9), which would increase the capacity of WAR9 to 55 dwellings.


These representations are submitted on behalf of the owners of this site, the Whitaker family. We can confirm that the site is available, developable and deliverable, as required by the NPPF. Indeed, it has been the subject of a recent appeal, which resulted in planning permission being granted for 50 dwellings (PINS ref. APP/R0335/W/17/3182713).

When the outline planning application for 50 dwellings was submitted (ref 16/01004/OUT), in October 2016, the site was designated as countryside, but not Green Belt. The application was recommended by planning officers for approval, on the basis that it

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comprised sustainable development, on the edge of a settlement and the council did not have a 5-year housing land supply. Members overturned the officers’ recommendation and refused the application, on the basis that the site was not in a sustainable enough location and development would harm the open countryside. Planning permission was refused on 23rd March 2017.

The decision was appealed and a Hearing was held in January 2018. The day before the Hearing, the council published the draft Local Plan, which included the proposed allocation of site WAR10. On 8th March 2018, the appeal was allowed for up to 50 dwellings, including up to 25% affordable housing, parking, public open space and landscaping, with access from Newhurst Gardens. All matters were reserved apart from access details.

The inspector found that the proposed low-density development, with a wide strip of landscaped public open space around the periphery of the site, acting as a buffer between the housing and the countryside, would be very well contained and would have a minimal visual impact on the surrounding open countryside (paras 12 and 13).

The site adjoins the northern side of Warfield Street, but because of the built-up road frontage the new housing would not be readily visible from many public viewpoints. The linear character of Warfield Street has already been compromised by the building of Newhurst Gardens, Toogood Place and Herschel Grange. The Character Area Assessment SPD states that future cul-de-sacs must be designed to minimise any impact on the street scene of Warfield Street. Development on this site will have a minimal impact on the street scene and the character of the local area.

The inspector concluded on this point (para 18), that the proposal would cause some limited harm to the character and appearance of the area and would have limited conflict with policies, which require development to be in keeping with the character of the area, protection of the character of local landscapes and wider countryside and respect local patterns of development. However, the limited harm he identified was not considered sufficient to dismiss the appeal.

With regard to the sustainable location issue, the inspector found that the site is not ideally placed in relation to local services and facilities (paragraphs 18 and 19), because, although Warfield Street is served by a regular bus service, the nearest shopping centre and primary school are 1.1km away. However, when he took account of the future development of new facilities as part of the major Warfield allocation of 2,200 homes, to the south of the appeal site, he found that this would result in a new primary school 500m away and neighbourhood centre 800m away. Once the new development is built-out, within a few years, the site would be ideally located in

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relation to services and facilities (para 21).

Regarding other issues, the Inspector found that concerns expressed regarding increased vehicular traffic, impacts upon heritage assets, trees and wildlife in the local area, were unfounded (paras 22 to 30).

In conclusion, the inspector found that although the development would have a minor environmental impact in relation to the character and appearance of the area and, in the short term, sustainable travel (para 36), these negatives would be outweighed by the benefits of the development; principally the delivery of 50 new homes, including 25% affordable, which would help to address the current housing delivery shortfall in Bracknell Borough.

The site is now proposed for allocation in the Local Plan for 96 dwellings (34 affordable), which we consider would be an even more suitable and sustainable use of the site.

The planning application, which resulted in the appeal, was for only 50 dwellings on a 4.43ha site, which equated to a gross density of only 11.3 dwellings per hectare or just 22.6 dwellings per hectare net (assuming 50% of the site is developed). The allocation in the local plan assumes a developable area of 3.2ha, which equates to a net density of 30 dwellings per hectare. The council is not consistent between sites, in terms of density. Some of the allocated sites are proposed at 25dph, some at 30dph and some at 35dph. If this site was developed over an area of 3.2ha at a net density of 25dph, this would deliver 80 dwellings, while at 35dph it would result in the delivery of 112 dwellings. While a scheme of 80 dwellings would be likely to be acceptable, we consider that 112 dwellings would probably be excessive for this site.

If this site were developed, as the council is suggesting, with about 75% of the site (3.32ha) developed and about 25% open space (1.11ha), this would still leave room for a considerable buffer of landscaped open space around the site boundaries. This proposal would deliver a landscaped buffer, which would contain the development within well-defined natural boundaries and ensure that it creates a smooth transition from the settlement of Warfield Street in the south to the open countryside to the north.

We consider that development for an increased number of dwellings (up to 96 at a net density of 30dph with 25% of the site kept as open space) would be achievable on this site. One of the major benefits of building at a higher density on more of the site would be the delivery of 34 affordable homes, compared with the 12 or 13 approved by the appeal inspector. These additional affordable homes would represent a significant social gain for the people of Bracknell.

One of the main constraints facing many potential development sites

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is the need for disparate owners to collaborate and agree to deliver the site for development at a given time. In many cases this proves difficult and in some cases, it results in sites never coming forward for development at all. This will not be the situation with this site, because it is owned by several members of the same family, who have all agreed that they want to see the site developed as soon as possible.

Overall, the site is suitable for the proposed number of dwellings, as it is in a sustainable location and it can be developed without causing unacceptable harm to the open countryside, highway safety, trees, ecology and heritage assets.

The allocation of site War10 for up to 96 dwellings should remain in the local plan, because, as required by the NPPF, the site is available, developable and deliverable.

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Responses to Section: 6.2. Residential/mixed use development/Policy LP3. Site WINK15 – Whitegates, Mushroom Castle, Chavey Down Road


Site WINK15 – Whitegates, Mushroom Castle, Chavey Down Road






Winkfield Parish Council (ID569- 578)

Major changes to the access would be required. No community gain from this proposal, just more pressures and strain on local infrastructure and facilities. Would not support this proposal.

There is no indication of any proposed additional employment on the above site.

No development of retail, leisure and other commercial development indicated.

Concerns relating to access via a very narrow lane and the impact the development will have on other roads, as the bus service in this area is minimal and car movements will be high.

No community gain detail is provided

No detail provided on climate change mitigation, and the adaption, conservation and enhancement of the surrounding landscape.



Bartlett (ID861) Loss of green fields.

CHARACTER

Bartlett (ID861) Overcrowding of buildings, not in keeping with other properties in Mushroom Castle.

Bartlett (ID861) Loss of views for houses bordering the field.


None received.


Bartlett (ID861) More run-off, adding to existing waterlogged ground.

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Responses to Section: 6.2. Residential/mixed use development/Policy LP3. Site WINK15 – Whitegates, Mushroom Castle, Chavey Down Road



TRANSPORT

Chavey Down Residents Association (ID456), Andrews (ID1185), Gunn (ID1214), Fazey-Gunn (ID1237)

Mushroom Castle is a narrow lane which will not allow two vehicles to pass/cannot be widened to accommodate two cars.

Chavey Down Residents Association (ID456), Bartlett (ID861)

Increased traffic and disruption along Chavey Down Road.


Bus service minimal, so car movements will be high.


Connecting through Carnation estate will create a rat run.

Bartlett (ID861) Cumulative traffic impact with other sites behind the original ribbon development along Chavey Down Road.

Andrews (ID1185) Local roads cant cope/cannot be improved (Braziers Lane, Locks Ride)

Andrews (ID1185) No detail on how public transport will be improved.

INFRASTRUCTURE

Andrews (ID1185) Lack of existing infrastructure, including lack of GP surgery within Winkfield Parish.

OTHER MATTERS

Bartlett (ID861) Development of the site would not be a benefit to the local community.

Andrews (ID1185) Where will additional population be employed?


Wessex Environmental Planning on behalf of Vanderbilt Strategic (landowner) and Persimmon Homes (ID765)

On behalf of owners/prospective house builder.

Support the inclusion of the site. Pre-application in the process of being prepared.

Figure 22 shows a proposed settlement boundary smaller than the SHELAA site boundary. To avoid any doubt that serving infrastructure can carry to the SHELAA boundary (subject to tree protection), the revised settlement boundary should be amended to meet the SHELAA boundary.

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Responses to Section: 6.2. Residential/mixed use development/Policy LP3 Site WINK20 – Former Landfill Site, London Road


Site WINK20 – Former Landfill Site, London Road




Natural England (ID113) Recommend that wording is added in order to ensure the protection and enhancement of the Public Right of Way at the northern end of the site.


Wastewater treatment works unlikely to support expected demand from the site. Likely to need significant infrastructure upgrades, ensuring sufficient treatment capacity is available to serve this development. TWUL welcomes opportunity to work with BFC and developer to understand and plan for sewage treatment infrastructure for this development. Should not under estimate time for infrastructure delivery, e.g. 18 months to 3 years to design and build Sewage Treatment Works upgrade. Can be up to 10 years to implement new technologies, construct major treatment works extension or new treatment works. Wastewater network capacity is unlikely to support expected demand from the site. Likely to need strategic drainage infrastructure ensuring sufficient capacity is brought forward ahead of the development. Where wastewater network capacity is a constraint, developers to liaise with TWUL and provide a detailed drainage strategy with planning application, informing what infrastructure is required, where, when and how it will be delivered.



McCulloch (ID3) Removal of gap between Bracknell and North Ascot (local identifies of local communities should be kept).

Singleton (ID63) Loss of Local Gap (as identified in the Entec 2006 study, and referred to in the Core Strategy Inspector’s report), resulting in coalescence of Bracknell and Ascot. (Comments also refer to WINK 22 (Whitmoor Forest), Palm Hills Estate and The Brackens).

CHARACTER

McCulloch (ID3) Site contains a rare rural footpath.


McCulloch (ID3) Whilst was a landfill, now contains mixed woodland and wildlife. Singleton (ID64) Development of the site would ignore the Habitat of Principle

Importance as identified in the NERC Act Section 4.1.


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Singleton (ID64) Proposals (including projects in two Boroughs) will impact the A329 London Road and add more than 200 extra cars, how will this be dealt with? (Reference made to the following development proposals: Berkeley Homes at Sunningdale Park; Ascot Centre, Heatherwood Hospital, Former Landfill Site, London Road, Palm Hills Estate, Whitmoor Bog, and The Brackens).

Wallen (ID844) Table 21 (relating to requirements contained in appendix). What is the remediation of WINK20?

TRANSPORT

None received.

INFRASTRUCTURE

Menon (ID1225) Significant increase in housing with no facilities shown.

OTHER MATTERS

Buffet (ID17) Development of the site for 278 houses will exacerbate concerns raised in relation to the WINK22 site.

Buffet (ID17, 44.) Queries why the site is included, when the 2016 SHELAA concluded that the site was not developable in the next 15 for a number of reasons, including potential contamination from landfill, would be contrary to proposed Local Plan policy LP44 (development on land potentially affected by contamination). The ability to comply with the policy has not been addressed in detail, and remains uncertain.

Buffet (ID90) Account should be had of combined impacts of developments (WINK 20 – former London Road tip, and WINK22 – Whitmoor Forest) , and changes of existing permissions once permission has already been granted (increasing housing numbers, such as Brackens applications to increase original permission by 9%). Applications to increase numbers on the proposed sites could be made, which would tip the balance against the sites.


Woolf Bond on behalf of Hodson Developments (ID916-922), JPP and Neal (ID896), Flavia Estates (ID915), JPP Land (ID 912), Warfield Park (ID1290)

Object to the allocation of the site. Lack of robust evidence demonstrating that the site can be viably redeveloped taking account of the contamination in the site alongside the additional cost of providing a link road through the site.


Table 21 of the Plan indicates the development would need to make a financial contribution towards off-site SANG, yet the draft Thames Heaths SPA SPD indicates that a development of this scale would be expected to provide a bespoke SANG. The SHELAA analysis suggests that the capacity of the site is 228 dwellings, based on a 6.51 ha developable area and the provision of 4.21 ha of on-site

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SANG.

As there is ambiguity as to how the development of this site would protect the integrity of the Special Protection Area and accord with the Habitats Regulations, the capacity and developabilty of this site is called into question.


On the basis that there is no evidence as to the extent of the remediation works that would be required at this site and no indication as to whether appropriate funding is in place, question whether there is sufficient evidence that this site could be developed, and capable of being viable.

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Responses to Section: 6.2. Residential/mixed use development/Policy LP3. Site WINK34 – land to the rear of Forest View and Oriana, Longhill Road, and west of Fern Bungalow (extension of site allocated through Policy SA3 of the SALP) Responses to Section: 6.2. Residential/mixed use development

Site WINK34 – land to the rear of Forest View and Oriana, Longhill Road, and west ofFern Bungalow (extension of site allocated through Policy SA3 of the SALP)







None received.


Boyer (on behalf of Shanly Homes) (ID1345)

On behalf of Shanly Homes (controls land at Palm Hills). Extended allocation is welcomed, however we consider the developable area is overly conservative and fails to maximise the development potential of the land.

Land submitted through the call for sites relates to two parts (a) land to the rear and north-east of Forest View on Longhill Road, and to the rear of Glendower and Engledene on London Road (with an area of 0.22ha); and (b) land to the north-west of the SA3 allocation. We understand that the second parcel (b) was also submitted as part of site Wink20. The draft Local Plan has only included the first parcel (a). The SHELAA states that no capacity has been applied to the land to the north-west of the SA3 allocation “due to constraints relating to trees, landfill and highway safeguarding”, however no further details have been provided.

SHELAA has not been informed by a detailed tree survey. Landfill cannot be considered as a constraint, when the Plan proposes to allocated WINK20 , former landfill site.

Consider the wider site can accommodate 71 dwellings.

Table 22 should be increased from a net 6 dwellings to a minimum of 25 net dwellings.

(comments also summarised on omission sites)

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Responses to Section: 6.2. Residential/mixed use development/Policy LP3. Site BIN7 – Land south of Foxley Lane and west of Whitehouse Farm Cottage, Murrell Hill Lane


Site BIN7 – Land south of Foxley Lane and west of Whitehouse Farm Cottage, MurrellHill Lane





Binfield Parish Council (ID254) It is contrary to Policy BF2 (Protection of Heritage Assets) of the Binfield Neighbourhood Plan (September 2015) in that it will impact the setting of the grade II listed Whitehouse Farm Cottage. Impact is out of proportion to the very small gain from five houses.


Binfield Parish Council (ID254) Foxley Lane is a narrow road, which carries a lot of traffic (vehicles coming from the Wokingham direction use the lane as a way of avoiding congestion at the roundabout in the centre of the village) and will be less able to cope without upgrading access at both ends of Foxley Lane.

Binfield Parish Council (ID254) The site is vulnerable to flooding. Binfield Parish Council (ID254) Murrell Hill Lane is part of a rambler’s route and is likely to be used

by recreational walkers. Opposed to the loss of this lane as a quiet place to walk. Development here will impact on the rural nature of Murrell Hill Lane. Reference is made to the reasons for refusal in the Foxley Oaks appeal decision (Appeal Ref: APP/R0335/W/17/3177088).

Binfield Parish Council (ID254) Questions whether any of the proposed developments in Murrell Hill Lane should go ahead given the outline planning permission granted at Pope’s Farm. This site could be removed from the Local Plan without any impact on the housing numbers required.




COUNTRYSIDE/GREEN BELT/GAP/LANDSCAPE

Bury (ID305), Butcher (ID982) Although site is small, makes an important contribution to landscape character of area. Wild scrub and mature trees / hedgerows important to the landscape character of the area; soften boundary between urban edge and open countryside.

Bury (ID305) Agree with Landscape Character Assessment that potential impacts on landscape character and views need to be considered, and plan to minimise these through careful siting and design, materials, landscape mitigation.


Contributes to setting of Binfield Village (along with rural lane, protect trees and historic hedgerows); setting being destroyed year

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on year. Should be preserved for future generations. Site links to Binfield’s rural past.

S Runham (ID495), Burchell (ID751)

Foxley Lane appeal refused because any development would be detrimental to the character and landscape of the area; sensitive location – major focus on landscape character harm. BIN8 was determined to be wrong scheme in wrong place; argue BIN7 is the same.

Burchell (ID751), Burchell (ID887)

Strategic need to respect the setting of the site in this edge of settlement location.

Reed (ID607) This area of the village is out of the settlement. CHARACTER

Bury (ID305), Hinton (ID1247) Site is in middle of ‘The Whitehouse Farm cluster’; development of site would be inappropriate and be out of keeping with surrounding area.

Bury (ID305) Concern about some existing buildings being located slightly below ground level and impact of proposed development impinging on privacy, cause adverse impact on amenity of adjoining occupiers by reason of overlooking, loss of light and adverse visual impact. Considered unacceptable and could be very intrusive to existing residents.

Bury (ID305) Site is uncultivated scrub land accessed off rural lanes. Bury (ID305), Reed (607), Hinton (ID1247)

Fringe area adjoined by very low density residential development. Currently 5dph density; proposal for 25dph considered wholly inappropriate for rural character of area and sparseness of existing built form. Will destroy setting of the heritage asset. Object to Council assuming 6 dwellings suitable, when landowner promoted 5 dwellings. Result in urbanisation.

Bury (ID305) Agree with Landscape Character Assessment that potential impacts on landscape character and views need to be considered, and plan to minimise these through careful siting and design, materials, and landscape mitigation.

Bury (ID305), Burchell (ID751), Burchell (ID887)

Land should be retained as open and undeveloped; constraints mean site not suitable for development. Site should be deleted as potential housing site for 6 dwellings.

S Runham (ID495), Reed (ID607), Butcher (ID982)

Site is off quiet rural lanes (Murrell Hill Lane, Foxley Lane) – whole aspect and character of lane would adversely change due to urbanising features. Murrell Hill Lane rural in ambience, attractive and undeveloped no-through road. Character of lane confirmed at the Foxley Oaks appeal; reference to ‘bulwark against urbanisation’ being noted at inquiry. Proposal adds pressure to fully urbanise Murrell Hill Lane at expense of character and relevance.


Murrell Hill Lane used by local people for dog walking, ramblers, exercise, riding and to enjoy natural undeveloped peacefulness of the lane.


Bury (ID305), Burchell (ID751), Burchell (ID887)

Site is in middle of ‘The Whitehouse Farm cluster’, which is a sensitive area with origins from 16th century. Setting of heritage asset is considered to be a crucial consideration. Provided historic

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maps showing cluster for years 1883, 1909 and 1944. Bury (ID305), Runham (ID495), Whitehouse Farm is Grade II listed (former farmhouse; listed 07 Dec Reed (ID607), Burchell (ID751), 1966); development of site would be inappropriate and be out of Burchell (ID887), Butcher keeping with surrounding area. Walls of property include windows (ID982), Hinton (ID1247) and are part of the boundary of the site. Development would

overwhelm listed building. Building would have originally been surrounded by open countryside and orchards (provided historic map evidence). Binfield village considered to have encroached on setting to the north; further urban sprawl proposed at BIN8 to southwest. To preserve rural situation and historic links, considered very important to retain open and undeveloped land around heritage asset. Proposed development of site would result in substantial harm to Grade II listed building, its setting and enclave of historic dwellings in vicinity (houses here were all associated with historic farmstead). Considered contrary to NPPF para. 133; harm not outweighed by social benefits from provision of small number of dwellings. NPPF also cited (para. 132 and 134) in relation to importance of settings. Considered unsustainable. Listed building entry summary provided (no: 1390288). Development would sever Whitehouse Farm cottage connection to its historical adjacent setting.

Bury (ID305), Reed (ID607) Site understood to have previously / recently formed an orchard associated with farmhouse; should be considered to be within the curtilage of the listed building.

S Runham (ID495), Reed Contrary to Binfield Neighbourhood Plan policy BF2 – protection of (ID607), Butcher (ID982) heritage assets, due to proximity to Whitehouse Farm Cottage.

Proposal does not sustain and enhance the setting as required by policy.

Reed (ID607) Enlarging village to include this historic settlement area will be to detriment of the listed asset.

Hinton (ID1247) Historic England state regarding cumulative impact to heritage assets that ‘negative change could include severing the last link to part of the history of an asset or between the asset and its original setting’.


Bury (ID305), Runham (ID495) Wild scrub and mature trees / hedgerows offer a diversity of wildlife habitats (some trees protected; hedgerow historic); object to loss of important wildlife habitats and protected species. In surrounding area there are breeding birds, foraging bats assemblages, grass snakes and great crested newts (based on EIA screening request submitted with app. at BIN8); consider these species likely to be found at BIN7 in view of habitats (wildlife scrubland, trees, meadow, woodland areas around Popes Meadow / adjoining rural lanes).

Bury (ID305) Site considered likely to function as an important wildlife corridor and biodiversity links due to edge of settlement location, adjacent open countryside. Link to Local Wildlife Sites.

Bury (ID305) Close to a number of Local Wildlife Sites.

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Development would fragment green infrastructure assets and create barriers to movement of people, biodiversity and water through the network (contrary to draft Policy LP38).


Bury (ID305), Runham (ID495), Butcher (ID982), Hinton (ID1247)

Site constrained by flooding; site has potential flood risk. High risk of surface water flooding (link to EA flood warning provided).

Hinton (ID1247) Bespoke borehole pumping system runs daily to move water from Whitehouse Farm. Believe runoff from development of the site would cause further issues.

TRANSPORT

Bury (ID305), Hinton (ID1247) Concerns about more traffic on already dangerous roads (Foxley Lane and Murrell Hill Lane). Will struggle to cope in the future due to cumulative impact of developments (i.e. Blue Mountain).

Reed (ID607), Butcher (ID982) Access to the site from Murrell Hill Lane and Foxley Lane will introduce urbanising features and adversely affect their character.

Hinton (ID1247) Will result in further overflow parking on Foxley Lane from the site at proposed densities.

INFRASTRUCTURE

None received.

OTHER MATTERS

Bury (ID305), Reed (ID607), Reed (ID608), Butcher (ID982), Hinton (ID1247)

Objects to existing properties being included within the defined settlement boundary; would prefer to remain outside the defined settlement. Site adjacent to the heritage asset will become the focus of future planning applications. Proposed new settlement boundary cuts across registered titles recorded by HM Land Registry. Consider that properties should be included in their entirety.

Bury (ID305) Understand site promoted by landowner and no developer / house builder involved.

Bury (ID305) Advises there was requirement imposed on other buildings in the area to be restricted in height and sunk below ground level in order to achieve two storeys.

Runham (ID495) Contrary to Binfield Neighbourhood Plan policy BF2. Runham (ID495), Butcher (ID982)

BFC opposed development at Foxley Oaks Inquiry, arguing development would be detrimental to the character and landscape of the area – perverse and contradictory to now suggest BIN7 can accommodate future development.

Reed (ID607), Burchell (ID751), Burchell (ID887), Butcher (ID982), Hinton (ID1247)

Limited number of new houses proposed will be of negligible benefit to village and borough. Unnecessary urbanisation for only 5 dwellings. Site should not be allocated.

Burchell (ID887) Cites Inspectors report for BIN8 (APP/R0335/W/17/3177088) and

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considers similarities, including Landscape Character harm and would result in the ‘wrong scheme in the wrong place’.


None received.

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Responses to Section: 6.2. Residential/mixed use development/Policy LP3. Site BIN10 – Popes Manor, Murrell Hill Lane


Site BIN10 – Popes Manor, Murrell Hill Lane





Binfield Parish Council (ID254) This site is close to Popes Manor, forecourt and garden wall (all grade II listed) and, according to the Binfield Landscape Character Assessment, PLCa4, “the whole area is important, valued landscape setting to Binfield”.


Binfield Parish Council (ID254) Strongly oppose the development if the access is from Murrell Hill Lane. The proposed development abuts Popes Farm and it should be accessed from that development. The argument for these developments to be accessed via the new traffic light junction is strengthened if these additional dwellings are to be included in the local plan.

Binfield Parish Council (ID254) Murrell Hill Lane is part of a rambler’s route and is likely to be used by recreational walkers. Reference to comments on site BIN7 which also apply.

Binfield Parish Council (ID254) Questions whether any of the proposed developments in Murrell Hill Lane should go ahead given the outline planning permission granted at Pope’s Farm. This site could be removed from the Local Plan without any impact on the housing numbers required.

Thames Water Utilities Limited (ID1527) On current information do not envisage concerns regarding wastewater infrastructure capability in relation to site.



None received.

CHARACTER

S Runham (ID495), Butcher (ID982) Concerns rural nature, local character and landscape of Murrell Hill Lane would change - local residents use it for general enjoyment, exercise and wellbeing. Addition of approx. 30 cars would remove rural ambience and change character.

S Runham (ID495), Butcher (ID982) Foxley Oaks appeal (BIN8) Inspector confirmed rural nature of Murrell Hill Lane and attractiveness of walkers and ramblers. BFC professional representatives argued the same.

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Responses to Section: 6.2. Residential/mixed use development/Policy LP3. Site BIN10 – Popes Manor, Murrell Hill Lane

RESPONDENT (NAME/ORGANISATION & OBJECTIVEREFERENCE ID)



S Runham (ID495), Butcher (ID982) Object to site being used for housing as would significantly damage setting of Grade II listed Popes Manor (small country house C17th origins with relatively intact historic parkland setting, allowing appreciation of both historical and architectural quality of the building).


None received.


None received.

TRANSPORT

S Runham (ID495) Murrell Hill lane small country lane could not cope with extra traffic.

INFRASTRUCTURE

None received.

OTHER MATTERS S Runham (ID495) Council should use brownfield sites first; several have been

put forward for development. Concerned more green open spaces around Binfield, Warfield and Winkfield will be lost for future generations.


None received.

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Responses to Section: 6.2. Residential/mixed use development/Policy LP3. Site BIN12 – Land south of London Road (Eastern Field)


Site BIN12 – Land south of London Road (Eastern Field)




Binfield Parish Council (ID254) Access should be from access road to London Road and not directly onto London Road.




None received.


Barton Willmore on behalf of Willson Developments Ltd (ID945)

Support the allocation of the site., on the following basis:

• The site is accessible, and good proximity to bus stops • Located to the south of the Amen Corner North site which

includes a primary school, recreation, open space and Suitable Alternative Natural Greenspace

• No obvious constraints to limited the deliverability of the site • The site is in single ownership, and could be developed in

the next five years.

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Responses to Section: 6.2. Residential/mixed use development/Policy LP3. Site BRA11 – Bus Depot (Coldborough House), Market Street


Site BRA11 – Bus Depot (Coldborough House), Market Street







None received.



Inconsistency, the Draft Plan relates to 212 dwellings, whereas the SHELAA refers to 236 dwellings and 3,050sqm of employment. The proposed density exceeds the SHELAA methodology. No developer is involved in the site. Therefore question whether completions will occur in 2028/29 as set out in the trajectory (Appendix 1 of the Draft Plan).

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Responses to Section: 6.2. Residential/mixed use development/Policy LP3. Site BRA12 – Former Bus Depot, Market Street


Site BRA12 – Former Bus Depot, Market Street








The land to the reverse of the cinema and side of Market Street. Seems vacant other than brick pallets and building materials. Could be a used for apartments



Inconsistency, the Draft Plan relates to 92 dwellings, whereas the SHELAA refers to 70 dwellings and 2,350sqm of employment. No developer is involved in the site. Therefore question whether completions will happen as set out in the trajectory (Appendix 1 of the Draft Plan).

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Responses to Section: 6.2. Residential/mixed use development/Policy LP3. Site BRA14 – Jubilee Gardens and British Legion Club, The Ring


Site BRA14 – Jubilee Gardens and British Legion Club, The Ring







CHARACTER

Mac Hale (ID486) Green space needs to be retained – space to relax/mitigate pollution.


None received.


None received.

TRANSPORT

Mac Hale (ID486) Adequate provision for parking is required (myth that those who live close to town centres do not possess cars).

INFRASTRUCTURE

Lunn (ID139) As there are so many elderly people in Bracknell, there is a great need for a hall near the buses. There could be shops, offices on the ground floor, a hall and kitchen on the first and apartments above.

OTHER MATTERS

Mac Hale (ID486) Applaud the provision of affordable housing – developments should not be able to get out of 35% obligation.


Turley on behalf of Bloor Inconsistency, the Draft Plan relates to 144 dwellings, whereas the

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Responses to Section: 6.2. Residential/mixed use development/Policy LP3. Site BRA14 – Jubilee Gardens and British Legion Club, The Ring



Homes Ltd (ID1435) SHELAA refers to 86 dwellings and 5,700sqm of employment. The proposed density exceeds the SHELAA methodology.


Inconsistency, the Draft Plan relates to 144 dwellings, whereas the SHELAA refers to 86 dwellings.

The Housing Background Paper (page 150) refers the site not having passed the sequential test, so a Level 2 SRA is required, which could impact the developable area of the site.

The Background Paper also refers to the site currently providing publicly accessible open space, therefore it will be necessary to demonstrate that existing open space is surplus to requirements.

No clear justification as to why a higher capacity of 144 could be achieved. Unless evidence provided, the capacity should be amended to 86 dwellings as indicated in the SHELAA.

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Responses to Section: 6.2. Residential/mixed use development/Policy LP3. Site BRA15 – land east of Station Way and North of Church Road (Southern Gateway)


Site BRA15 – land east of Station Way and North of Church Road (Southern Gateway)







None received.


Turley on behalf of Bloor Inconsistency, the Draft Plan relates to 267 dwellings, whereas the Homes Ltd (ID1435) SHELAA refers to 145 dwellings and 9,400sqm of employment. The

proposed density exceeds the SHELAA methodology. No developer is involved in the site. Therefore question whether completions will occur in 2030/31 as set out in the trajectory (Appendix 1 of the Draft Plan).


The Draft Plan relates to 267 dwellings, whereas the SHELAA refers to 145 dwellings.

The Housing Background Paper (page 157) refers the site not having passed the sequential test, so a Level 2 SRA is required, which could impact the developable area of the site.

The Background Paper also refers to the site currently providing publicly accessible open space, therefore it will be necessary to demonstrate that existing open space is surplus to requirements.

No clear justification as to why a higher capacity of 267 could be achieved. Unless evidence provided, the capacity should be amended to 145 dwellings as indicated in the SHELAA.

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Responses to Section: 6.2. Residential/mixed use development/Policy LP3. Comments about proposed development (omission sites, and new sites promoted through the consultation) Responses to Section: 6.2. Residential/mixed use development/Policy LP3. Comments about proposed development (omission sites, and new sites promotedthrough the consultation)




Binfield Parish Council (ID254) WAR3 Jealotts Hill International Research Centre, and land at Jealotts Hill, Maidenhead Road

The NPPF states that development of brownfield sites should be prioritised over previously undeveloped greenfield sites. Syngenta, Jealotts Hill, have a long term plan to turn the facility into a research and development headquarters with a reduced footprint and develop the site. If this is not agreed, Syngenta may leave the country with a net loss of jobs. Excluding this site from the local plan is a missed opportunity – offers a major opportunity in terms of housing and the upgrading of infrastructure in the local area plus improved access to the M4. Whilst it is a Green Belt site it is a “brownfield site”.

Sandhurst Parish Council (ID1120)

WAR3 Jealotts Hill International Research Centre, and land at Jealotts Hill, Maidenhead Road

There are no very special circumstances to justify the complete redevelopment of this site when there are sufficient sites available to take the LPA’s short medium and long term housing needs elsewhere. Any significant development of this site would set an unacceptable precedence. There is also no guarantee that putting the majority of the housing for the plan period on this one site would limit development elsewhere as the sites already identified elsewhere can still come forward, and if approved would double the number of houses being built to more than required.


J Sinclair (ID489), S Runham WAR3 (ID495), Higgins (ID505), V Jealotts Hill International Research Centre, and land at Jealotts Baker (ID509), R Warren Hill, Maidenhead Road (ID540), J Clark (ID976)

Land at Jealotts Hill/Syngenta (brown field site) would be a suitable alternative (to BIN5 and 6) as a higher number of dwellings could provide local community resources/services e.g. doctors, shops, school to overcome distance from existing services.

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Responses to Section: 6.2. Residential/mixed use development/Policy LP3. Comments about proposed development (omission sites, and new sites promoted through the consultation)



A Osborne (ID555) WAR3 Jealotts Hill International Research Centre, and land at Jealotts Hill, Maidenhead Road

Syngenta which would more than absorb the development of BIN6 and others in Binfield. Would also mitigate the continual disruption being caused by local development work being spread across almost all major access routes.

L Dunnett (ID757) WAR3 Jealotts Hill International Research Centre, and land at Jealotts Hill, Maidenhead Road

Syngenta is a brownfield site with good access to public transport and the M4 with space for housing in a sustainable location which should be prioritised over green spaces sites in Binfield.

V Baker (ID509) BIN4 Wyevale Garden Centre, Forest Road

Wyevale Garden Centre site at risk of flooding (same as BIN5 and BIN6) but discounted/not included.

J Clark (ID976) BIN4 Wyevale Garden Centre, Forest Road

Not included but has been offered.


WAR8 Land between Newell Hall and Cuckoo Cottage, Warfield Street

Oppose the allocation of WAR8 which, in tandem with WAR9 and WAR10 would have a significant detrimental impact upon the character and setting of Warfield Street. It may have an impact on the adjacent Newell Hall, which is listed. It is out-with the settlement boundary; Grade 3 (possible 3a) Agricultural Land Classification; and mixed use consisting of trees. Allocation of this site would render the northern edge of the settlement indefensible.

J Clark (ID976) What other brownfield sites have not been included?


Fellbon Property Company Ltd.(ID867)

SAND2 Land south of Sandhurst Lodge

Object to omission as:

Site is between and opposite significant existing residential development.

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Development would not impact upon the strategic gap between the Crowthorne and Sandhurst and would be screened from Wokingham road by existing vegetation.

Site is close to Crowthorne and Sandhurst and would not have a ‘poor relationship’ with those settlements.

The Council’s Landscape Sensitivity Appraisal states that overall the sensitivity of the site was considered to be low-medium.

Accept that there is a risk of flooding.

Trees with TPOs are in poor condition. Trees are located around the perimeter of the site. Invasive rhododendrons are currently overwhelming the existing flora and fauna.

Doubt that the site is of medium ecological value due to invasive rhododendrons. Development could improve biodiversity and allow for the removal of the rhododendrons.

Topography of site would not prevent development from a technical point of view.

The site could accommodate much needed housing that the Council has failed to provide for a number of years.

Souter (ID447) WAR 4 and WAR 5 . Land east of Binfield Road

WAR 4 (1.34ha) to be considered with WAR5 under the control of Persimmon Homes Thames Valley Limited. The combined area of the two sites is about 18.18 ha with a capacity for about 150 dwellings. Development would be limited to the lower slopes of Cabbage Hill and served from the existing Binfield Road/Temple Way roundabout.

Wish to promote WAR 4 for a care home, as alternative option.

Hodson Developments (ID924) WAR20 Land at St Michael’s Grange, Osborne Lane, Warfield

Object to omission as site is within the control of a developer who can deliver homes (approx. 137 at a medium density) at an early stage.

The Council’s Heritage Assessment refers to the Grade II Listed St Michaels Grange and Barn & Cottage adjacent to the Grange and the Grade II Listed Newell Hall which lies south of the site. However, development within this large site can be planned to respect the immediate settings. Needs to be balanced against the

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wider housing need in the Borough in view of shortfall (too short a plan period, unjustified medium windfall figure and lack of evidence to support Derby Field, former London Road Tip and land south of London Road).

Potentially a sustainable location.

The Council’s landscape assessment confirms that the site has capacity to accommodate visual change without significant harm. Refers to appeal decision on land north of Newhurst Gardens, Warfield (appeal ref APP/R0355/W/17/3182713) and references to other sites having breached settlement boundaries.

Beaulieu Homes Southern (ID587)

WAR 24 Scotlands House and Campground, Forest Road, Warfield

The site is 1.19ha. New dwellings could be built within the grounds of Scotlands House utilising the existing access road through the site. It should be seen in the context of developments in the surrounding area. Adjacent to the entrance is a plot (previously known as Brooklyn) where 3 dwellings are under construction. Various residential and commercial properties are located along the south side of Forest Road. It would form a logical extension of the strategic site at Warfield (a new access onto Forest Road is close to the site) where additional services and facilities will be provided.

The site is well located close to Bracknell town centre and its facilities and services and is served by a bus stop 100m from the site.

All development could be located within the southern part of the site that is Flood Zone 1.

The site is deliverable and available for development - a planning application (12 dwellings and open space) is currently being considered by the Council (18/00047/FUL). It will provide a much needed small site.

Napper (ID86) Owner of WINK19. Land between London Road and Longhill Road

WINK19 and 20 are adjacent and characteristics and ecology are similar but the two sites have been treated differently in the draft Plan. Clear area of WINK20 is proposed for housing, despite major works necessary to treat landfill. Clear area (c.0.3ha) of WINK19 has not been recognised.

This could accommodate 6 houses without loss of trees, is flat with no known constraints and could be developed quickly. It has a substantial entrance and access to services in the road. Previously

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pointed out in comments on the SHELAA (final draft) (ID39). This is substantiated by the Council’s ecological evidence (CLP/EV/8a), page 805 which confirmed the extent of the clear area and page 813 confirmed that it has a ‘low level of ecological constraint’.

The clear area of site WINK19 has also been submitted under the ‘call for small sites’ by the Winkfield Neighbourhood Development Plan Steering Group.

Boyer (on behalf of Shanly Homes) (ID1345)

On behalf of Shanly Homes (controls land at Palm Hills). Extended allocation is welcomed, however we consider the developable area is overly conservative and fails to maximise the development potential of the land.

Land submitted through the call for sites relates to two parts (a) land to the rear and north-east of Forest View on Longhill Road, and to the rear of Glendower and Engledene on London Road (with an area of 0.22ha); and (b) land to the north-west of the SA3 allocation. We understand that the second parcel (b) was also submitted as part of site Wink20.

The draft Local Plan has only included the first parcel (a). The SHELAA states that no capacity has been applied to the land to the north-west of the SA3 allocation “due to constraints relating to trees, landfill and highway safeguarding”, however no further details have been provided.

SHELAA has not been informed by a detailed tree survey. Landfill cannot be considered as a constraint, when the Plan proposes to allocated WINK20 , former landfill site.

Consider the wider site can accommodate 71 dwellings.

Table 22 should be increased from a net 6 dwellings to a minimum of 25 net dwellings.

(comments also summarised on WINK34)

Harvey, V (ID713) Owner of omitted part of WINK14 (3 acres west of Braziers Lane at the southerly (Forest Road) end, between Tiles Cottage & NRM).

Object to omission as:

The proposed primary school and school facilities would prevent the use of this adjoining land for equestrian purposes (the grazing and rearing of young horses or horses recuperating from serious injuries). In both cases a very quiet rural environment is essential.

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The inclusion of the land would enhance the facilities for the proposed school and the green areas.

Eustace (ID 1370) Owner of omitted part of WINK14

Has interest in the industrial site located along Braziers Lane. Very surprised this land has been excluded from the draft allocation

All the land between Braziers Lane and the proposed allocation, should be included in the allocation and in the new settlement boundary. Braziers Lane is a clear defensible boundary and it is illogical to not include this land within the allocation now, especially as the site is brownfield land. Although the site is not available for development in the short term due to an existing tenancy, it is a large brownfield site with clear development potential and would easily become available for development within the timeframe set in the draft Plan. Issue has been discussed with the landowners of the land to the south and they have confirmed they will also make their land available for development as part of an allocation.

Flavia Estates (ID915) Owner of Site WINK18 Land at Whitegates, Longhill Road, Winkfield

Under the control of a developer who can bring site forward early. Discounting land covered by TPO, developable area is .55ha.

Although an appeal relating to 14 dwellings on this site was dismissed, the context has changed following an appeal decision relating to 82 mobile homes at Warfield Park. Quote para 14 of Inspector’s decision letter …. ‘units would not be unduly incongruous or uncharacteristic‘.

Consider that 13 bungalows would help meet distinct housing needs and could be appropriately accommodated, reflecting the transitional nature of the areas character – the interface between Warfield Park Home site and the countryside to the east (illustrative landscape strategy submitted). Landscape and Visual Impact Assessment has been prepared for the site which highlights the significant degree of enclosure and limited impact. Also refer to para 35 of Inspector’s decision letter relating to land north of Newhurst Gardens, Warfield where reference is made to the breach of firm settlement boundaries having occurred. Opinion from Michael Bedford QC submitted stating that there having been material changes in circumstances since the 2017 appeal.

Jones (ID600) WINK 24 Land at Woodstock, Kings Ride, Winkfield

The site and surrounding area is currently within the Green Belt. It was assessed in the joint Green Belt Review (June 2016) but forms

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part of a wider parcel of land (B22 and more specifically 22b). The report states that, overall, the parcel provides a significant contribution to the Green Belt

However, the findings are challenged as the site is not considered to meet the purposes of the Green Belt since it is partially developed. Refer to paras 80 and 83 of the NPPF plus para 133 draft NPPF.

Due to persistent under delivery of housing in the Borough and the increased OAN, consider that the alteration of Green Belt boundaries in certain appropriate locations should be considered as a critical source of housing land supply in the face of potential significant shortfall.

Have assessed the site in detail against the Green Belt purposes.

Row (ID379) Owner of Site WINK 26 Swinley Edge, Coronation Road, Winkfield

Object to omission as: Disagree with the conclusion that all sites should be located outside the Green Belt.

The Green Belt Review adopts a flawed methodology due to the scale of the parcels. As a result it fails to take account of anomalies in the Green Belt boundary.

Swinley Edge was included as part of a wider parcel of land (B24a) which comprises a large swathe of predominantly undeveloped land. The boundaries of the parcel appear to be based on administrative boundaries and do not consider the characteristics of sites within it. The boundary does not follow an identifiable physical or man-made feature. A site visit should have taken place.

Due to the site's relationship with South Ascot, within which it partly lies, the level of new development in the area and natural containment, Swinley Edge should have been identified as a separate sub-parcel. The land makes a limited contribution to the purposes of the Green Belt. National policy refers to the need for permanent and defensible Green Belt boundaries.

The Plan is not justified and therefore not sound as the evidence base used for decisions on site allocations is flawed. Sites are proposed which are less sustainable and which are of higher ecological value and subject to flooding.

Marplace Ltd (ID452)) WINK 29 Land south of Forest Road and north of Rhododendron Walk

Site should be allocated for a small mixed-use development, to

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include 24 market houses and 11 affordable houses, two new schools (infant and junior) and a nine-hole golf course (site masterplan included).

The supporting Infrastructure Delivery Plan 2017 (page.16) identifies Ascot Heath as a primary school that could experience pressure due to new developments in neighbouring authority areas. However, the draft local plan only focuses on the school pupils who will be living in the new residential developments that are planned. Fails to recognise situations where existing school sites are constrained and buildings are at the end of their life. In these cases, the Local Plan should identify sites for new schools to replace existing schools. Refer to para 95 of Draft NPPF to support this.

The Draft Local Plan should look beyond creating and expanding schools and should also consider situations where there is a need to alter schools. Primary school provision in the Ascot Heath catchment is served by the Ascot Heath Infant School and the Ascot Heath CE Junior School - share a single site and occupy aging buildings, which require significant investment in maintenance. Share a small sports pitch, which falls below current standards. This proposal provides an opportunity for the schools to relocate just to the north of their current location onto a much larger site, currently in agricultural use. This would enable the delivery of new, purpose-built school buildings and greatly improved sports pitch provision.

Wyevale Garden Centres (ID753)

Owner of Site BIN4 Wyevale Garden Centre

Highlight positive assessment of the site within the 2016 SHELAA and disappointment that site not proposed for allocation. Other sites proposed in Binfield are greenfield and in the countryside and less sustainable.

Point out that site remains suitable, available and achievable. It is in single ownership and existing use could be discontinued.

It is PDL with a variety of buildings / structures / hardstandings and only 0.6 miles from Binfield centre and services. Well placed to take advantage of existing sustainable modes of transport. Not located within any special landscape or heritage designations. Strong natural boundaries, especially along the eastern boundary.

Could be redeveloped for residential (1st preference) and / or employment purposes - could provide at least 35 dwellings or 5,600sqm of employment floorspace. Site should be included within the settlement boundary for Binfield

Redevelopment could result in an improved layout and better

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landscaping which would have a positive impact on the rural character and integrity of the countryside.

CBRE Ltd on behalf of Hewlett Packard Enterprise (ID 904)

New sites BIN18 & BIN19 Cain Road, Binfield

Comprises 3 parcels: 1) Main Site - approx. 7.5ha and features a three storey linked building that was constructed pursuant to a 1988 planning permission. 2) Recreational Site’ – greenfield site of approx. 2.5ha (south west of the main site). 3) Island Site – approx 1.88ha allocated for housing in the SALP.

Site no longer meets operational and locational requirements. - Office layout is out of sync with both current and future working environments; - Considerable amount of vacant floorspace and under-occupation:

o HPE occupies approximately 37% of floorspace; o Microfocus is on a short-term lease and occupies 6% of

floorspace; o HPI occupies 11% but it is believed that they will be

relocating; o DXC leases 24% of floorspace but space is currently vacant

and is being actively marketed. - Also element of communal space.

HPE is not looking to cut numbers of employees (currently c. 600). Requires a flexible workspace environment of around 30,000-40,000 sq ft in a more sustainable location within a town centre position. Will improve the accessibility and attractiveness of the business for staff.

Employees wish to be located in well serviced locations with access to a range of facilities, particularly retail, leisure and public transport. The location and environment of office stock is critically important to businesses being able to retain and attract staff. This reflects a structural shift away from the stand-alone business parks of the 1980’ and 1990’s.

3M (ID1104) New site BIN16 3M United Kingdom PLCLand between Cain Road and Turnpike Road (0.85ha)

• Available for residential development – could be delivered in next 5 years.

• Involves land used for staff sports and social facilities ancillary to 3M office campus (to be replaced elsewhere on campus).

• Brownfield site in sustainable location within settlement.

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• More sustainable and better aligned to the Council’s spatial strategy than other sites proposed for allocation.

• Residential development nearby. • 2 existing access points (Turnpike Road and Cain Road). • Forms part of Western Industrial Area but 3M do not intend to

build further employment floorspace on this land. • At least 30 dwellings per hectare would be appropriate in view of

the need to make effective use of the land and respect local character.

Chance (ID658 and 659) New Site BRA16 Pinecroft, Old Wokingham Road

• 0.63ha of land currently occupied by house and associated stables.

• Promoted for C3 (4/5 bed houses at 16-25dpha) or C2 use.

Bewley Homes PLC (ID1322) New Site SAND8 Eagle House Field Site, Crowthorne Road, Sandhurst

Promotion of site for C2 use, accessed from Crowthorne Road. The use of the site to meet the needs of residents with dementia and limited mobility would be compatible with Thames Basin Heath Special Protection Area and Site of Special Scientific Interest, subject to strict occupancy controls secured by planning condition.

Site is in a highly sustainable location adjoining the settlement boundary of Sandhurst and close to centres. Nearby bus stops enable access to services into Sandhurst, Crowthorne, Camberley and Bracknell.

Scheme could be designed so that it is in keeping with its setting and does not have an adverse impact on the surrounding area including amenities of neighbouring properties.

Scheme could accord with draft Policy LP22.

Thakeham Homes Ltd (ID598) New Site at White Cottage, Forest Road (outside Borough boundary)

Collaborative approach should have been taken in considering housing allocations situated along the administrative boundary with Wokingham Borough. Makes reference to West of Berkshire Spatial Framework (para 36), where it is acknowledged that there is a need to consider land along the border between the 2 Authorities.

Site of 4.09ha which is considered to be PDL. Stated that it is physically and perceptually tied to Binfield. Unconstrained and should be assessed as being suitable, available and deliverable.

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JPP Land Ltd (ID914) New Site BIN17 Land north of Tile House and Honeysuckle Cottage, TilehurstLane

Site of 0.6ha should be allocated for 9 dwellings (indicative site layout submitted – 15 dpha) as extension to site with outline planning permission (15/00452/OUT) for 28 dwellings granted upon appeal in 15 March 2017. Within the control of a developer who can bring site forward early in the Plan period.

Principle of residential development accepted through appeal process. Site layout feasibility plan submitted that shows access could be provided through adjacent consented site.

Hodson Developments (ID923) New Site WAR25 Land north and east of Steeple View, Gibbins Lane, Warfield

2.3ha site within the control of a developer who can deliver homes during the early years of the plan period.

Could be allocated with land currently proposed for allocation to the south (War9 and War10). Settlement boundary could incorporate this additional land. Could be allocated for around 44 dwellings

Refers to appeal decision on 8 March 2018 for the erection of up to 50 dwellings on land north of Newhurst Gardens, Warfield (appeal ref APP/R0355/W/17/3182713).

Bellway Homes (ID1438) New site: Land to the south west of Binfield and north west of Amen Corner North (no map submitted)

Land straddles the administrative boundary and is being promoted to Bracknell Forest as well as Wokingham Borough.

Site is equidistant between the centres of Bracknell and Wokingham and adjacent to the settlement of Binfield - therefore accessible to a range of services and facilities as well as key aspects of the strategic road network.

Site is also free from many environmental and other constraints unlike other sites in the Borough.

Development would be capable of providing new infrastructure and of meeting the housing needs of the two authorities and the wider HMA.

Bewley (ID 1472) WAR12 Brookfield Farm, Bracknell Road, Warfield – 60 (21)

In order to rectify the under provision of housing sites (see submitted

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Housing Evidence Paper), land at Brookfield Farm, Warfield should be allocated for approx. 60 homes (incl. 21 affordable).

Comprises a commercial equestrian business (4.1 hectares). It is a previously developed site that incorporates the following facilities; - A 20m×40m Indoor Riding school. - International sized outdoor arena. Flood lights and a Soft Track all weather surface. - Dormit Canter Track. - All weather, 30m×80m jumping arena. - A Claydon, 5 horse walker for exercising the horses. - An All-weather lunge arena. - Horse treadmill. - Large, well-lit and ventilated stables.

It is therefore a previously developed site that incorporates these facilities.

Accompanying Landscape & Visual Appraisal describes in some detail the appearance of the site, and its contribution to the existing landscape character.

Bewley Homes now have an interest in the site. As a result, the ability to develop the site, if allocated, is clearly enhanced.

The site’s SA scores compare favourably with some of the sites proposed for allocation so it’s not clear why it’s an omission site.

Only limited weight can be afforded to the emerging Neighbourhood Plan and local gap proposal. Even if/when the Neighbourhood Plan is published the proposal could adhere to the Local Gap policy.

The Landscape and Visual Appraisal explains why a landscape led scheme would not detract from the character of existing settlements or result in coalescence. Impact upon the landscape character of the area will be acceptable.

The site performs better on fluvial and surface water flood risk than many of the allocated sites. Whilst it is noted that a small part of the site, towards the south west corner, falls within Flood Zones 2 and 3, this does not mean that development cannot be introduced without any detrimental impact upon flood risk.

Whilst the presence of trees, including protected, is acknowledged, this is one of the reasons why a landscape led scheme, that retains trees, is the way in which development can and should come forward at the site. Not a reason to prevent development.

There’s a reference to potential impact on the setting of the adjacent listed building. This conflicts with the Council’s own detailed

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comments on the issue, which recognises harm will not be caused.

The developer recognises that the potential for contamination from a nearby landfill site will need to be carefully and properly addressed prior to any development taking place. However, as demonstrated by the allocation of many sites that include landfill sites within or near to them, this is not a reason to resist allocating the site.

It is stated that the site contains a mineral deposit. However, this applies to a number of the allocated sites and is not a reason to resist allocation of the site.

The site is considered to perform very well in terms of accessibility, with better proximity to, and connectivity with, existing and future facilities. There is direct and dedicated pedestrian and cycle access to the Tesco superstore, only 600m to the south west of the site, and the adjacent local centre including a library and Doctors surgery. The Council’s assessment suggests that the closest primary healthcare facilities are not accessible by foot, but this is not correct, given that the Gainsborough Practice, which lies 750m to the south west of the site, can be accessed via the dedicated footpath and cycle way (Edmunds Lane).

Souter and Persimmon TV (ID 1508)

WAR4 and WAR5 Land north of Binfield Road, at Temple Park Roundabout, south west extremity of Cabbage Hill.

Agricultural land owned by (i) Persimmon Homes (16.79ha) and (ii) Mr G. Souter (1.34ha). Aggregate area of 18.18ha. Access to the site is via the Souter Family Land, on its south flank, alongside Binfield Road.

Warfield SPD shows these two blocks of land as SANG passive open space provision. Consider suitable for 150 homes (4.94 ha, leaving 13.0 ha for passive recreation alongside and stretching northwards to Cabbage Hill), with access via the Souter land. The land is available for development within a 3 year time-scale i.e. prior to 2021.

Consider the site to be better related to Bracknell Town and the major highway network than some other sites proposed for allocation and Jealotts Hill. Consolidates seamlessly with the Harvest Ride development clusters - similar scale of development and rhythm of housing clusters could be achieved westwards of the linear woodland/south of the SANGS open space.

SANGs calculation should not pivot on the simple calculation that 8ha per 1,000 population is immutable. The Warfield SPD indicates a linked network of open spaces and recreational zones across its extensive east to west borders. There are therefore considerable

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opportunities for passive recreation without the need for full reservation of Persimmon’s Cabbage Hill land (lower slope only) for open space.

Seems likely that there will be proposals to redevelop Jealotts Hill Research Centre during the plan period, which may include housing. The site is remote and is comparatively poorly served by the rural road network. Best used for a retirement village, rather than for main-stream / family housing. This type of facility would be low traffic generating and, to a large degree, self-contained. Jealotts Hill should not be considered for general housing provision.

JPP Land (ID 913) Existing allocation Land north of Tilehurst Lane, Binfield

Object to omission of this site as principle of residential development was established in approval on appeal of application 15/00452/OUT (28 dwellings). The site should be included within the settlement boundary for Binfield on the Council’s policies map.

Policy LP1 seeks to maximise the efficient use of land. In view of this, we have looked at reviewing the approved scheme to establish whether an alternative development could be accommodated upon the site (broadly reflecting the form and layout of development within the illustrative layout) whilst increasing the number of units (smaller dwellings). Plan enclosed (no. 2254/01F) compares a potential revised layout (60 dwellings). Density would be 17.80 dph which is low compared with other allocations of between 30 and 35 dph.

Would make a valuable contribution towards addressing the identified housing need that complies with the 15 years post adoption strategy of the emerging NPPF.

Woolf Bond on behalf of Flavia Estates and JPP Land Ltd (ID903)

SAND4 Land south of High Street and east of Yateley Road, Sandhurst

Land is within the control of a developer who can bring it forward early in the Plan period.

Access could be off High Street or Yateley Road. The northern part of the site (around 0.8 ha) is suitable for residential development (medium density) whilst the remainder (approximately 1.6ha) could be retained and enhanced for its ecological interest and potentially made available to the wider community through an appropriate mechanism that supports and enhances its biodiversity value.

The Council’s SFRA (Feb 2018) indicates that the northern part of the site which is proposed for allocation is wholly within Flood Zone 1. Consequently, the site is not at risk of flooding.

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As Sandhurst Parish contains around 17% (2011) of the Borough’s dwelling stock, it is surprising that there are no allocations. Plan shows lack of regard to the population of Sandhurst contrary to paragraph 67 of the draft NPPF The sustainability of the site was recognized in a pre-app response from the Council dated 18th March 2016 in respect of 15 dwellings (BPRE/15/00239/PREPREZ).

As the Council needs to find sites to address the identified shortfall of at least 3,828 dwellings between 2013 and 2036, the allocation of the northern part of Sand5 would contribute to this.

Barton Willmore on behalf of Harrison Housing (ID1063 & 1065)

Owners of WAR8 Land between Newell Hall and Cuckoo Cottage, Warfield Street

Consider the site (0.51ha) to be deliverable in the short term for 100% affordable housing. Reference made to the site being open, with trees of mixed quality along the boundaries, which has been recently covered by a TPO following a pre-application enquiry

Consider the site to be suitable for housing as it within 400m of a new local centre and 500m of a new primary school to be delivered as part of the Warfield allocation. The sustainability of the site is confirmed by the close proximity of WAR9 and 10 which are included in the draft Local Plan.

The Sustainability Appraisal (also summarised in evidence base) includes reasons for not allocating the site, addressed below:

Local Gap. Note the emerging Warfield Neighbourhood Plan has not yet been submitted to the Council, nor draft consultation carried out, nor assessed by an independent examiner. Therefore it should not be afforded significant weight. Comments also made on the principle of allocating a gap within a neighbourhood plan. There is no basis for gaps within the NPPF or PPG, or revised NPPF. Reference made to the independent examiner report on Sonning Common Neighbourhood Plan which recommended a gap policy was deleted.

Surface Water Flood Risk. Note there is a small high-risk area on the eastern boundary. Any development would be stepped away from the boundary due to significant tree coverage. In addition, subject to a drainage strategy, impermeable areas would be minimised, and Sustainable Drainage Systems incorporated.

Adjacent to Listed Buildings. The indicate layout takes on board comments from the Council’s heritage through the pre-application. A significant western buffer would be retained with additional planting to ensure the setting of the

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listed building is protected, and a proposed L-shaped building to be subservient to the listed building.

Site covered by trees. The site is not covered by trees, the majority of trees are located close to the boundaries. This is supported by a tree survey. Whilst there are saplings within the centre of the site, the trees of higher quality are around the boundaries, and could be retained as part of any development.

Medium Ecological Value. A preliminary note provided which recommends mature trees and vegetation around the boundaries are retained to support pipistrelle bats. The note also recommends further work is undertaken to ascertains whether ponds in the area surrounding the site support Great Crested Newts. Further work undertaken by EPR with E-DNA show no ponds with a Great Crested Newt within 250m of the site, and no further surveys recommended.

Landscape Sensitivity. Any development would incorporate existing tree coverage as well as adding trees on the western boundary to create a buffer with the listed building. The proposal would consist of a large single building set back in the suite, consistent with neighbouring buildings. The site should be viewed in the context of the north Bracknell strategic allocation, located south of the site.

Representation accompanied by the following: • Drawings (including site plan and proposed layout) (Barton

Willmore) • A local precedent study (Barton Willmore) • Tree Information Report (Ian Keen Limited) • Tree constraints plan (Ian Keen Limited) • Transport Technical Note (i-Tansport)

Woolf Bond Planning on behalf of Warfield Park (ID 1282, 1283, 1284, 1285, 1287)

WINK17 Land at Chavey Down Farm, Long Hill Road

Site adjacent to WINK17 was granted planning permission on appeal (September 2017) for the change of use of land adjoining Warfield Park for the siting of up to 82 mobile homes.

Request this site is allocated for residential development of c. 60 dwellings. The site includes a house, commercial stables and outbuildings so is consider to form in a part a previously developed site. The site is in the control of Warfield Park, so could be bought forward for park homes on conventional C3 use.

Reference made to para. 22 of the appeal decision in relation to

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recognition of the role that this part of the Borough plays in meeting the needs of the elderly. Non-allocation of WINK17 does not accord with para. 50 & 62 of the NPPF which indicate policies should identify size, type and tenure of homes for different groups.

The omission site forms an accessible location (reference made to paras 21, 23-32 of the appeal decision) for development, adjacent to a site which already benefits from residential permission, with potential for highway safety improvements, partly previously developed, and should be allocated for 60 units.

(Also see comments on Policy LP11 and Appendix 2).

Kevin Scott Consultancy on behalf of Home Farm Land Ltd (ID1359)

WAR23 Land at and adjacent to Home Farm, Forest Road, Warfield

Submission forms a slightly different boundary to that put forward in the call for sites process. Comprises a 13ha greenfield site of open fields (the adjacent farmstead complex does not form part of the site). Consider the site is well located to complement the redevelopment of land at Warfield (Policy SA9) and would form a logical extension to it (being located north of the existing allocation).

Proposed development could incorporate c. 250 dwellings, new access from Forest Road and open space. The site is considered suitable, based on consideration of landscape value and access/highway impacts. In summary, the following benefits of the site are put forward:

• Adjacent to the North Bracknell extension and less than 100m away from the built development on this site. This site will take advantage of all the sustainable benefits of that site.

• Abuts the current SANG provision in the area while benefiting from delivery of its own SANG which is not reliant on any third party (Long Copse)

• Excellent highway and pedestrian connections to the Bracknell town centre and the wider area

• Within walking distance to the proposed new local centre • Good public transport to Bracknell, and the wider area

including Crossrail services in Maidenhead • Site in one ownership so easily deliverable • Landscape-led design extending the urban area and soft

landscaping the remainder of the site to provide a buffer to the surrounding countryside

• Provision of affordable housing Representation accompanied by the following:

• Landscape Appraisal (Illman Young Landscape Design Ltd) • Highway Technical Note (Odyssey)

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RESPONDENT COMMENTS RECEIVED (NAME/ORGANISATION & (SUMMARY OF MAIN ISSUES RAISED) OBJECTIVE REFERENCE ID)

Boyer on behalf W J Channing & Sons (Woking) Ltd (ID1379)

WINK30 Land at The Rough (including Pineways, The Victory and 32-42 New Road, Ascot)

Supports the intention of the Green Belt. The site falls within land parcel B20 of the ‘Green Belt Review’ (Amec, June 2016), and is categorised as making a contribution to the Green Belt, in particular “forms an important part of the separation of Bracknell and North Ascot”. The site only forms a small part of the parcel, and is not considered on its own merits, and is bounded on threes side by residential development, if considered to make little if no contribution to the 5 purposes of the Green Belt.

In the absence of a detailed assessment of the site, the site has been considered against the five purposes of the Green Belt:

• To check the unrestricted sprawl of large built-up area As the site is contained by residential development on three sides it is pocket of inaccessible land in a built-up area. Development of the site would not result in unrestricted sprawl of the urban area, and would result in a logical rounding off site, strengthened by trees on the western boundary.

• To prevent neighbouring towns merging into one another Development of the site would not extend any further west of the existing residential development to the north and south. Retention of trees along the western boundary would visually contain the development, so no visual coalescence with Winkfield Row to the west.

• To assist in safeguarding the countryside from encroachment An amendment of the Green Belt boundary to follow the western boundary of the site would create a defensible boundary to the Green Belt which could be supported by the retention of a strong mature tree belt along this boundary.

• To preserve the setting and special character of historic towns Residential development on The Rough would be within an area which has a general suburban character and would not therefore have any impact on the setting and special character of a historic town.

• To assist in urban regeneration, by encouraging the recycling of derelict and other urban land Although development of The Rough would not assist in meeting this purpose of the Green Belt, the scale of development likely to be proposed on the site would not materially reduce pressures to develop derelict and other urban land within the authority.

Release of Green Belt land should be in locations which are close to settlements and within reasonable distance to transport connections.

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Consider the site fulfils this, located just north of Ascot High Street and west of Ascot train station. In a sustainable location with access to a wide range of local facilities. Forms as logical rounding off extension to North Ascot with logical defensible boundary. Overarching need for housing represents exceptional circumstances to justify the release of the site from the Green Belt.

Reference made to site submission form and comments made on the Consultation on the Final Draft Strategic Housing and Economic Land Availability Assessment (SHELAA) Methodology and Results, and Draft Site Selection Methodology (November-December 2016).


SAND3 Land south of Ambarrow Lane, west of Wokingham Road, and east of Lower Sandhurst Road

Site is approximately 29.6ha, and has the potential to accommodate an indicative capacity of 400-500 dwellings, and on-site SANG.

Information provided on site context such as the site being bound by road, and comprising existing field parcels in agricultural use, a watercourse and drainage ditches transect the site (though it is not identified as significant risk of fluvial flooding, and contains a number of large mature trees. Biodiversity features include a Local Nature Reserve (Ambarrow Court) which extents to the north west of the site. The site adjoins the existing built edge of Little Sandhurst. However, do not consider the site to be as constrained as other sites at and around Sandhurst.

Consider the site to be in a sustainable location, access to a wide range of services and facilities, such as education, shops, localised employment and rail station, with links to public transport.

Do not consider there to be constraints which would inhibit development, in summary:

• Archaeology – The Assessment provided indicates that the site has ‘low archaeological potential’ and is not constrained by any statutory (below ground) heritage assets.

• Ecology – There are no serious constraints to development that could not be overcome by sensitive scheme design and the development of appropriate mitigation measures. On-site ecology surveys are on-going.

• Access Opportunities and Constraints – The associated Access Opportunities and Constraints document and Technical Note (provided in support of this submission) indicates that safe and suitable points of vehicular access can be achieved.

• Utilities – The accompanying Utility Report and Thames Water response identify the presence of elements of utilities infrastructure provision on or vicinity of the proposal site, with

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the relevant third party infrastructure provider issuing advisory information. Such information has informed the indicative

The site is deliverable, with client background in a strong position to deliver a significant level of new housing.

A comparison of the site against other allocated sites also undertaken in relation to LP4, LP5, LP6, LP7 and SAND5.

Representation accompanied by the following:

• Wokingham Borough Council Consultation Response • Site Location Plan • Agricultural Land Quality (Reading Agricultural Consultants

Ltd) • Archaeological Desk-Based Assessment (CgMs Ltd) – • Access Opportunities and Constraints (Phil Jones

Associates) • Wokingham Road – Access and Sustainability Note Rev B

(Phil Jones Associates) • Thames Water Response • Utility Report (Groundwise)

Turley on behalf of Knight and Alfred Homes (ID1446)

WINK7 Ronans, Forest Road, Winkfield Row

Site is an area of unmanaged grassland, previously used for grazing, to the east of Ronans, grade II listed house.

Information provided on site context such as the site being enclosed by mature trees, and a road to the south and east, and a tree preservation order on part of the site.

The site is considered to be suitable in the context of sustainable development:

• Economic: housing will contribute towards the local economy through provision of construction jobs in the short term, and additional council tax in the longer term.

• Social: The draft Plan does not categorise settlements by way of a hierarchy. Winkfield Row is served by a good range of services and facilities (school, recreation ground, hall, farm shop and restaurant). There are a range of other services (doctors, dentists) accessible by public transport.

• Environmental: development can seek to create improvements e.g. Landscape Planting Plan, Surface Water Drainage Strategy, Ecological Mitigation.

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Consider the site to be suitable, confirmed by recent nearby applications at Land at the Yard, Chavey Down Road for 4 proposed dwellings (ref 15/00200/FUL) and at Land rear of Neuchatel Chavey Down Road for 5 proposed dwellings (ref 16/01153/FUL).

(Also summarised in evidence base). Reference made to the planning application information accompanying application 17/01051/FUL, which were not considered as part of the Sustainability Appraisal process. Comments made on the sustainability appraisal of the site in relation to:

• Landscape sensitivity. LVIA submitted demonstrates that the King George V Recreation Ground makes the greater contribution to the perceived openness of the area; the village character; and, the break between areas of residential development, than the site.

• Poor relationship to existing settlements. LVIA submitted for application 17/01051/FUL demonstrated that the proposals are visually contained from the wider landscape and do not contribute to the visual separation of Winkfield Row North and Winkfield Row South.

• Forms the setting of adjacent grade II listed building – medium heritage value. Having considered the limited extent to which the application site contributes to the special architecture and historic interest of Ronans and the character and appearance of the Winkfield Row Conservation Area, together with the Landscape Strategy and the form and appearance of the proposed development in 17/01051/FUL, the Heritage Statement concluded that there will be no harm to the significance of these heritage assets.

• Proximity to Conservation Area. As above.

• Groundwater and surface water flood risk. The Flood Risk & Drainage Assessment (Appendix 5) proposes a drainage solution involving an attenuation pond to the north west of the site providing further storage volume, upstream of the controlled outfall to the existing ponds. The proposed pond falls within public land, enabling long term maintenance.

• Protected trees on site. The AIA and Tree Protection Plan submitted with application 17/01051/FUL (shows the majority of existing trees being retained. Five trees are to be removed as they have been identified as being of a poor condition and not viable to retain. One small tree group and two individual trees are also proposed to be removed to accommodate the access road and construction activity. Given the potential for additional planting, this is not considered to be a constraint

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to delivery. A comparison of the site against other allocated sites also undertaken in relation to LP6 (land at Winkfield Row).


• Wokingham Borough Council Consultation Response • LVIA submitted with application 17/01051/FUL (Turley) • Landscape proposals submitted with application

17/01051/FUL • Heritage Statement submitted with application 17/01051/FUL

(Turley Heritage) • Flood Risk & Drainage Assessment submitted with

application 17/01051/FUL (Glanville) • AIA and Tree Protection Plan submitted with application

17/01051/FUL (Turley)

Turley on behalf of Berkeley Strategic Land Ltd (ID1494 & 1495)

BRA1 Land at Parkview Farm, Old Wokingham Road

Specific comments made on evidence base namely the Draft Sustainability Appraisal and Housing Background Paper (also summarised under evidence base).

Draft Sustainability Appraisal Broadly supportive of the overarching methodology, but question factors taken into account in scoring SA1 (mitigate climate change), SA12 (health), and SA17 (travel), resulting in double counting of scoring.

SA1 draws upon Appendix 1 of the Draft Transport Accessibility Statement do objectives SA16, SA17 and SA12. Implications of double counting are if a site scores well against criteria in the Accessibility Statement, the positive score is multiplied by a factor of at least two, and conversely if the site scores less well, the negative score is multiplied. Revised scoring provided to remove the bias. Consider that as the SA moves forward, double counting should be eradicated from the scoring.

The SA does not include comprehensive evidence or commentary on the scoring process that has been applied to each of the proposed allocations and excluded sites against the SA criteria (although notes the Housing Background Paper does provide some high level commentary pertaining to the scoring criteria included in Tables 12 and 13). For example scoring given to the land at Parkview against criteria SA6b – Wastewater, where a double negative result is recorded on the grounds that major constraints have been identified. The source and nature of the stated major constraint does not however appear to have been documented

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within the SA or the referred published Phase 1 Water Cycle Study (December 2017).

The key issues are the reasons given by the Council for not allocating the site include, which are disputed:

• the site has a poor relationship with the existing settlement • the site is an isolated location within the countryside in an

area that acts as a strategic gap • the site is judged to have medium-high landscape sensitivity • fluvial, surface water and ground water flood risk • presence of trees along boundaries • there are areas of high ecological value • the site partly contains a Local Wildlife Site/Ancient

Woodland • high historic landscape value and the presence and setting of

an adjacent listed building • within the setting of an archaeological asset • changes in level across the site, and • potential for odour from nearby Wastewater Treatment

Works. Comments on SA scoring:

• Objective SA1 – Mitigate Climate Change The site has the opportunity to provide sustainable development in relation to transport infrastructure, and good access to services. Preliminary transport strategy (TS) provide provided. This identified that contributions could be made from the site for joint highway safety improvement at the junction of Easthampstead Road/Old Wokingham Road and two other junctions at Old Wokingham Road/Waterloo Road and Wold Wokingham Road/Nine Mile Ride. The TS also identifies the opportunity to facilitate a bus loop through the site, and improved pedestrian and cycle connectivity. As per the Council’s Transport Accessibility, the site scores well in its locational sustainability. The TS concludes there are no transport related grounds why the site does not represent a suitable and accessible location for development, therefore consider it would have a neutral effect ion the SA objective overall.

• Objective SA3 – Biodiversity Phase 1 Ecological Appraisal has been undertaken on the sit. Which confirms the site is dominated by agricultural land of a mix of arable and semi-improved grassland which is of negligible to low ecological value. Within the contest of the site, the field boundary features are conclude to be elevated in value. Development of the site could therefore retain with appropriate reinforcement the boundaries of the site. The study also concludes that retention of the small areas of the

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onsite non-statutory designated Local Wildlife Site (LWS) small area of Ancient Woodland situated in the north of the site could be avoided through sensitive design layout. Therefore conclude that the site would have a limited negative impact on biodiversity connectivity and neutral scoring against the SA objective.

• Objective 4a – Landscape A Landscape and Visual Appraisal (LVA) has been undertaken on the site, and a rebuttal in relation to the Council’s assessment of the site. The LVA confirms the site is not visible from a wide surrounding area and the surrounding mature vegetation would be of benefit in providing early visual enclosure and partial screening of any built development on site, and there are no overriding landscape or visual constraints associated with the site that preclude development. It is acknowledged that the key sensitivity relates to the strategic gap between Bracknell and Wokingham, and the landscape setting of Easthampstead Park, but concludes that this can be addresses through location of development, and strategic planting belts to visually and physically enclose the site. Therefore, consider the site has a medium landscape sensitivity, and the development can include mitigation of impacts.

• Objective SA4b – Historic Environment A Built Heritage Assessment and Archaeological Desk Based Assessment (ADBA) submitted which concludes that Old Oak Farm, The Clockhouse and Old Oak Court (all Grade II), Locks House (Grade II*), Locks Barn, the barn at Sutton Court Farm and stables at Sutton Court Farm (all Grade II) are sufficiently removed and screened that the site does not currently contribute to their respective settings. Primary identified consideration relates to the setting of Easthampstead Park (Grade II), acknowledges there will be some impact to the setting through direct views from The Avenue, but could be mitigated by stepping development away from eth eastern boundary, and provision of strategic landscaping. Also recommends that the Bridleway crossing eth site should be retained as a footpath route to perverse its character as a historic route contributing to the setting. The ADBA confirms there are no designated heritage assets recorded on the site. The SA scoring should therefore reflect the above from a negative scoring.

• Objective SA9 – Economy and Employment Promotion of the site includes a new community facility, a health facility and co-working space and land for a new Primary School. Development of the site will therefore facilitate job creation and economic growth providing employment opportunities supporting a successful, competitive and balanced local economy for the area, and will have a positive impact, and the SA scoring amended.

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• Objective SA15 – Community The site is in close proximity to a range of facilities including local schools and facilities at Jennetts Park. Promotion of the site also includes on-site facilities. The SA scoring should take account of this and be amended from neutral to positive.

• Objective SA16 – Services Reference made to the Residential Accessibility Assessment used to assessment the sites. Sites BRA3 & BRA4 of +14 which has translated to a single positive score in the SA, where as this site overall score has translated to a positive and negative scoring. Comparative scoring appears misplaced, given that BRA3 & BRA4 are further away from strategic employment locations, centres and health facilities than Parkview Farm. Therefore either the scoring for BRA3/BRA4 should be downgraded to match Parkview Farm or vice versa.

• Objective SA17 – Travel Development of the site would dissipate traffic to the strategic road network and provide opportunities to secure contributions for junction improvements in the local area to the site. Pedestrian and cycle access can be accommodated within the development, bus route linkages can also be facilities. Therefore consider the site would have a positive effect on the SA objective.

Housing Background Paper • The site is judged to have medium-high landscape sensitivity

The overall assessment of landscape sensitivity value, should be medium and not medium high. Also see comments on SA.

• Fluvial, surface water and groundwater flood risk Based on the Level 1 Strategic Flood Risk Assessment (SFRA) a total of 0.9% of the site is in Flood Zone 3 and 0.2% is in Flood Zone 2. I n total 13.5% of the site area is at risk of surface water flooding and 8% is at risk of ground water flooding.

• Presence of trees and ancient woodland The site predominantly comprises arable and semi-improved grassland with limited coverage of woodland and trees. A small area of Ancient Woodland is present on site located in the northwest area and further woodland is located in the south in proximity to the pond. Beyond this trees are predominantly located along the site boundaries. The presence of trees and the small area of ancient woodland on the site is not considered to limit the proposed development capacity of the site.

• Areas of high ecological value and Local Wildlife Site The findings of the Phase 1 Ecological Appraisal confirm the site is considered to be highly deliverable in ecological terms

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• High historic landscape value and setting of adjacent Listed Building The findings of the heritage assessment conclude development of the site will not affect either heritage of archaeological assets or their settings due to separation and screening and due mitigating process during future construction.

• Changes in level across the site There are no significant and severe internal gradient changes that represent a technical limitation to delivery of development on the site, and this is not considered a reason not to allocate the site.

• Potential for odour from nearby Wastewater Treatment Works Whilst potential odour will require further detailed assessment, it is not considered to represent a significant issues. This is reflected in the proposed allocation of The Hideout and Beaufort Park (LP4) which is in close proximity to a treatment works, and Bog Lane/Swinley Road (LP5).

Comparative analysis against the four stra5tegic sites also undertaken – some comments summarised under individual sites:

• The Hideout and Beaufort Park, West Bracknell • Land south of London Road, east of Bog Lane and west of

Swinley, East Bracknell • Land at Winkfield Road, Winkfield • Land at Hayley Green, Warfield


• Transport Strategy Technical Note (Odyssey Markides) • Landscape and Visual Appraisal (Fabrik) • Landscape Rebuttal Statement (Fabrik) • Ecological Appraisal (Aspect) • Built Heritage Assessment (CgMS) • Heritage Rebuttal Statement (CgMs) • Archaeological Desk Based Assessment (CgMs)


BIN8 Land south of Foxley Lane and west of Murrell Hill Lane, FoxleyFields

A scheme for 380 dwellings on the site was recently dismissed on appeal (APP/R0335/W/17/3177088).

Notwithstanding the decision, not that the Inspector comments (para. 30) that an area wider than the appeal site alone has been identified as having some capacity for development, c. 30% (2010 Landscape

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Capacity Study). Whilst acknowledging that some of that capacity has been taken up by Amen Corner North "I do not seek to suggest that development there should rule it out elsewhere in the relevant area" and "what is important, as with any application or appeal, is that a judgement is made based upon the particular proposal, with landscape studies of whatever scale or purpose being used to inform and assist in the process of judgement. "

Inspector also concluded (para. 50) that the highway network has capacity to accommodation development, and impacts would not be severe (para. 48).

In relation to the strategic gap between Bracknell and Wokingham, the Inspector concludes (para. 57) that although there would be some intrusion into the gap, the perception of the separation of settlements would remain the same: "the harm to the physical and visual separation between Bracknell and Wokingham would be limited'.

Setting of Listed Buildings would be preserved (para. 68), only a small loss of agricultural land which did not weigh against the appeal (para. 68), no unacceptable harmful impacts to adjoining residential properties (para. 75), loss of trees would be low (para. 71) and adequate buffer to ancient woodlands would be maintained (para. 77).

In relation to air quality impact upon the Thames Basins Heath Special Protection Area, the Inspector concluded (para. 64): "no evidence which suggests that this proposal, either singly or in combination with other developments, would result in air quality thresholds or traffic thresholds being breached':

The proposal would provide for open space and SAND (paras 83 and 84).

On this basis, therefore consider there is clear evidence that an alternative residential-led scheme could be accommodated on the site. The site remains available, deliverable and suitable for residential development.

Baron Willmore on behalf of Syngenta (ID1376)

WAR3 Jealotts Hill International Research Centre, and land at Jealotts Hill, Maidenhead Road

Site promoted for a new Science and Innovation Apr, with sustainable new community comprising:

• C.4,000 new homes within a new sustainable new community based on Garden Village principles;

• C.95,400 sqm of new employment floorspace within a

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Science and Innovation Park (representing a net increase of 70,629 sqm);

• C.46,58ha of strategic SANG (providing two country park areas);

• Significant biodiversity benefits; • A new secondary school and up to 3 new primary schools; • A new local centre with retail and leisure facilities; and • Significant infrastructure enhancements including local

highway junction improvements including cycling and pedestrian links to the north of Bracknell Town, and increased appeal of public transport by increasing the frequency of the no.53 public bus service which runs between Bracknell, the Site and Maidenhead.

Syngenta consider the proposed development to be crucial in supporting continued investment in Jealott’s Hill into the future, although recognise that exceptional circumstances still need to be demonstrated to justify the amendment of the Green Belt boundaries in this location in order to accommodate the proposed development. A separate report, detailing the exceptional circumstances in support of the amendment of Green Belt boundaries around Jealott’s Hill has been included , which concludes there are a number of exceptional circumstances that support the amendment of the Green Belt boundary in this location to support the proposal. In summary, these include:

• Syngenta does nationally and internationally significant work • The UK agri-tech sector has been specifically targeted for

Government support. • Encouragement for Syngenta to sustain its current position

and support expansion of its activities and investments at Jealott’s Hill

• Syngenta’s values and our ambitions for Jealott’s Hill match the Clean Growth agenda in the Government’s Industrial Strategy.

• The potential for adding to local and national economic growth is considerable

• Significant provision of housing to help address the uplift in delivery to support growth in Bracknell of 610 jobs per annum, particularly 1,400 affordable homes

• Significant strategic country park/SANG of 46ha in the northern part of the Borough, adjacent to the recently implemented Frost Folly SANG providing a powerful draw away from the internationally protected heaths to the south of the town

• Significant sustainable community and social infrastructure • The site makes limited contribution to the function of Green

Belt

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Representation accompanied by the following studies:

• Jealott's Hill - Our Vision for a Sustainable Science Community (Executive Summary);

• Jealott's Hill - Our Vision for a Sustainable Science Community

• Green Belt Exceptional Circumstances report (Barton Willmore)

• Landscape and Visual Appraisal & Green Belt Review (Barton Willmore)

• Jealott's Hill, Bracknell: A Driver of Economic Growth in Berkshire and the UK (incorporating Economic Benefits Statement within appendix) (Wessex Economics)

• Built Heritage Statement (CGMS Heritage) • Utilities Overview(Abley Letchford Partnership) • Transport Assessment (Systra) • Technical Summary Note on Ecological Constraints and

Opportunities (Ecological Planning and Research Ltd) • Primary and Secondary Education Needs Analysis (EPDS

Consultants) • Flood Risk and Drainage Strategy (Abley Letchford

Partnership)

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Responses to Section: 6.3/Policy LP4. Land at the Hideout and Beaufort Park, Nine Mile Ride, Bracknell.





Natural England (ID114) The site is in close proximity to Broadmoor to Bagshot Woods and Heaths SSSI (also designated as Thames Basin Heaths SPA). Note the provision of SANG/SAMM to mitigate for recreational impacts in line with the Thames Basin Heaths Avoidance and Mitigation Strategy. Ecological assessments should be undertaken for this site to ascertain any other direct or indirect impacts on the SSSI/SPA, with these impacts being avoided or mitigated for where necessary.

Note that the south eastern corner of the site is very close to the boundary of the 400m exclusion zone. Advise that the site boundary is carefully placed on the Policy plan maps in order to exclude any part of the site which falls within the 400m zone.

Recommends that the Policy is amended to include wording to ensure the provision of Sustainable Drainage Systems (SuDS).

Binfield Parish Council (ID255) No comment. Crowthorne Parish Council Site at the Hideout have limited road improvements as shown in the (ID399) plan. The Hideout development road exits into Bracknell Great

Hollands, might be more appropriate than Nine Mile Road or Old Wokingham Road.


The site would generate a significant number of extra trips onto Nine Mile Ride (B3430) which extends westwards into Wokingham Borough and is known to be a congested road with few opportunities for upgrades. WBC wish to remain fully engaged with BFC’s transport modelling and Infrastructure Delivery Plan work to ensure that there are no significant detrimental impacts of planned development on Wokingham Borough. Potential CIL funding will need to be appropriately shared between BFC and WBC to contribute towards any necessary infrastructure improvements beyond Bracknell Forest Borough.

Concerned about the issue of future coalescence between the built up areas of Bracknell and Wokingham. WBC would be generally resistant to future planned developments which compromise the separation of the built up areas.

Wokingham Without Parish Council (ID804)

Aware of the need to respect and celebrate the distinctive communities on their border (WWPC is located in the strategic ‘triangle’ between the large towns of Bracknell and Wokingham and the smaller town/village of Crowthorne).

Strongly question the following: • Why the Bracknell - Crowthorne (and Bracknell - Binfield)

strategic gap has been omitted from section 11.2.12.

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• Why the distinctive settlement Crowthorne has not been maintained as a specific policy.

• Development in the strategic gap (LP4 Hideout/Beaufort Park).

• The logic behind the settlement extension of Great Hollands/Bracknell to include LP4.

• The intrinsic sustainability of site LP4 (even if the strategic gap policy was ignored).

Recommended the re-establishment of the ‘Triangle Forum,’ to deal with concerns relating to cross border collaboration.



Warfield Parish Council (ID671) Notes with interest no proposal for a school despite the size of development and its locality.

Bracknell Town Council (ID440, 441)

Support the inclusion of the sites, and the principle of comprehensive development.

Adequate access infrastructure is important. The southern access should tie in with the existing roundabout in Nine Mile Ride.

Provision of allotments welcomed, as there is a waiting list in Bracknell Town.


Noted.



Baster (ID146), Lester (ID349), The strategic gap between Crowthorne and Bracknell should be Rogers (ID363), Gourley reinstated/retained. The land forms the last remaining piece of (ID483), Wisniak (ID485), strategic gap between Crowthorne Village and Bracknell Town Thomson (ID498), Frampton (Great Hollands). The two communities would be divided only by a (ID579), Crowthorne Village single carriage way road. (Reference within comments to the Action Group (ID558), Gourley strategic gap between Crowthorne and Bracknell was identified in (ID593), Doran (ID602), Murphy the Core Strategy (2008), the Bracknell Forest Landscape evidence (ID626), Mischefski (ID850) (2015) – Table 4.3, and the Comprehensive Local Plan Issues and

Options (2016) – para. 9.1.2. Development of the Hideout would occupy the existing gap between Crowthorne and Bracknell. Reference to the Site Allocations Examination, and SALP Policy in relation to TRL and the Inspector’s comments on the gap, which was in danger of being eroded, and needed to be maintained, and the Council were required to amend the plans).

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Rogers (ID362) Site is outside current settlement boundary. Newland (ID367) Principles outlined in section 11.2.1 of the Plan being ignored for this

site. BFC needs to apply its own standards and principles to its Plan. The proposal for the site ignored policies and is indefensible.

Doran (ID602) Policy LP4 (page41) states ‘Land at the Hideout and Beaufort Park as shown on the Policies Map and illustrative Concept Plan is allocated for a comprehensive well designed development that maintains a gap between Bracknell, Wokingham and Crowthorne’, yet the gap is not listed on page 76. Also see comments made on Strategic Gap section of the Draft Plan in relation to this site.

CHARACTER

Rogers (ID362) No consideration to landscape boundaries between the Beaufort Park office and LP4.

Thomson (ID498), Frampton (ID579)

Plans will erode the character and identity of the area.

Crowthorne Village Action Group (ID558)

The strategic gap maintains the distinct identity of the village.


Brown (ID88) Council should be protecting woodland as a priority. Current proposals on the draft NPPF includes defined reasons for restricting development includes, aged or veteran trees, not just ancient woodland.

Lester (ID349) No contiguous green link between farm land to west and Swinley Forest, creating barriers to wildlife.

Frampton (ID579), Crowthorne Village Action Group (ID558), Doran (ID602), Murphy (ID626)

Loss of green corridor/wildlife habitat (since the construction of Bucklers Park on TRL site, this site provides the last remaining wildlife corridor between Swinley Forest and farmlands to the west), contrary to Draft Plan policies LP36 and LP38(v).

Wallen (ID823), Warfield Environment Group (ID1190)

Too many trees being removed in this area of Crowthorne, not appropriate to remove woodland, especially broadleaved.


SANG should leave the woodland as it is, and not turn into a field.

Mischefski (ID852) Woodland and scrubland is a habitat for wildlife. RSPB (ID1228) As part of the sequential approach to protecting important wildlife

sites, the Council should look to locate new housing away from the Thames Basin Heaths in order to avoid or minimise the recreational and other urban impacts, consistent with retained South East Plan Policy NRM6.

Lowland heathland is a priority for nature conservation. Opportunities to restore, increase and better connect the habitat is encouraged. The site allocation is a former lowland heathland, still supports small areas of heathland. Whilst it is noted these will be preserved, they will be isolated as part of development which will limit their value. The area has potential for heathland restoration,

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and given its proximity to the SPA, consider it inappropriate to allocate for 570 houses.

Whilst the policy contains provision of a bespoke SANG, question the ability of the area shown to function as an effective SANG givens its shape and fragmented nature.

Request the site is removed from allocation.


Vincent (ID69), Lester (ID349), Air quality in Crowthorne High Street is already 25% above legal Gourley (ID483), Gourley limits (reference to a CVAG newsletter), and this is before TRL is (ID593), Doran (ID602), Murphy completed. Indefensible for BFC to plan to make an already illegal (ID626) condition worse.

Other comments include: Additional traffic will worsen the issue. Should be a clear plan to divert traffic away from the High Street (existing AQMA) in Crowthorne, should be in place before Cluster 3 is built upon. Cumulative effect of new traffic from Bucklers Park and other sites in and around Crowthorne increasing NO2. More development bordering the SPA, will combined pollution from all sources be assessed?

Rogers (ID362) Environmental Health issues of housing proposed close to a sewage works and crematorium.

Thomson (ID498) Plans need to address improvements to air, light and noise pollution, and address the current air quality management areas.


Reference made to additional traffic and associated NO2 pollution (e.g. exit from the site on to the B3430 Nine Mile Ride and additional traffic which passes immediately adjacent to the perimeter of the Thames Basin Heaths Special Protection Area). Road is already congested, and more so with 1,000 houses at TRL, 1,500 in Wokingham Borough (Hogwood Lane and others at Arborfield). Full assessment of NO2 needs to be undertaken. It will also contribute some additional traffic to the Crowthorne AQMA, where, according to the 2017 Air quality report from BFC, NO2 levels are already 25% above the statutory limit.

TRANSPORT

Cllr Angus Ross (for Cllrs Sleight, Helliar-Symons and Ross: adjoining borough Councillors in the Wokingham Without ward, Wokingham Borough Council)

Accept the general suitability of sites, but have serious concerns regarding infrastructure impacts. No mention of traffic implications into WBC area, nor opportunities to provide further access and parking for Crowthorne train station (this needs to be identified in the approval, or a specific allocation from CIL).

Insufficient reassurance as to the traffic impact on Nine Mile Ride (already at capacity). Additional traffic will impede on traffic coming from the west, from WBC parishes. Not clear why access to Nine

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Mile Ride requires a second on roundabout to the TRL (concerns raised regarding additional access on Old Wokingham Road between WBC junctions). The Pinewood roundabout has already been enlarged, how can further enlargement improve capacity?

The Plan is silent on transport impacts and opportunities. In addition to parking issues at Crowthorne Station, bus access from the site to the station should be covered.

Vincent (ID69), Holt (ID124), Lester (ID349), Gourley (ID483), Frampton (ID579), Gourley (ID593), Wallen (ID823), Warfield Environment Group (ID1190)

Overdevelopment in the area (comments refer to combined impacts of other sites such as TRL, Charity Land site/Bewley site, Broadmoor). Consider that improvements to Pinewood roundabout, and roads cannot cope with existing traffic/congestion, let alone future. Will be worsened with additional housing on the site. Roads referred to in reps include: Nine Mile Ride, Old Wokingham Road, Peacock Lane.

Rogers (ID362) No transport links (including footpaths) to link the development to the settlement.

Rogers (ID362) Lack of capacity on strategic road network (M4, A329M, A322).

INFRASTRUCTURE

Rogers (ID362, 363) No on-site infrastructure planned. Thomson (ID498) Provision of services required such as doctors, sewage systems. Crowthorne Village Action Group (ID558)

Para. 6.31 refers to an existing vacant office building which is subject to a separate proposal for residential development (100 homes). Therefore, the infrastructure requirements for LP4 should relate to requirements for 670 new homes, not 570. The larger number may requirement support for shops, schools, medical care etc.


The site is shown as an extension to Bracknell Town and CIL will go the Bracknell Town Council. However, all exits go towards Crowthorne so residents will naturally gravitate towards using facilities in Bucklers Park and Crowthorne Village (ref made to Cluster 3, Fig 9, page 210)

Mischefski (ID850) Off-site infrastructure cannot sustainable the proposals.

OTHER MATTERS

Vincent (ID69), Mischefski (ID852)

Unfair treatment of the village, already had more than a fair share of Boroughs recent new housing/Crowthorne has been subject to extensive development.

Vincent (ID69) Queries that there are no more suitable sites available nearer to Bracknell Town.

Rogers (ID362) No consideration given to the building on the Beaufort office site, which is big enough for on-site infrastructure.


Site is isolated and not connected to either Bracknell, Wokingham or Crowthorne, not sustainable unless internal provision can be made for services to support an independent community.


This policy should be dropped as it is contrary to: - Local Plan Policy on maintenance of strategic gaps.

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- Maintenance of wildlife corridor. - Need to site new development so it does not add to problems in an existing AQMA. CVAG protecting our village against urbanisation If it is to go ahead in some form, then the council should either : a) Amend plan so exits are to Great Hollands ring road, or b) Amend settlement boundaries so it is an extension of Crowthorne and CIL goes to Crowthorne Parish. LP4 should be amended to add internal provision of additional services and infrastructure to support an independent community. A full assessment of NO2 levels along the B3430 boundary with the SPA should be conducted, including a projection of additional contribution from other planned developments in the area.


Comments in relation to Cluster 3 (page 210, Fig 9). See also comments on Policy LP4. Map is not up to date as it does not show development at Oakham Park, so is misleading in terms of residual gap between Crowthorne Village and proposed Cluster 3. Amendments: update map or amend plan so exist are to Great Holland Ring Road, or amend settlement boundary so it is an extension of Crowthorne and CIL goes to Crowthorne.

(Also see comments on appendices). Mischefski (ID852) Alternative brownfield sites should be found, and greenfield sites

protected. Collings (ID1068) Do not know the land sufficiently well to comment.


Terence O’Rourke for Tingene Parks Ltd (371), and Bracknell Land Ltd (ID391)

Promoters of site. Support identification of the site for approx. 570 dwellings in draft Policy LP3/LP4. Note that the actual capacity will be determined once further work on the implications of flood and ecological mitigation has been undertaken, and can confirm that this work will be undertaken shortly, it is therefore possible that more than 570 could be accommodated on the site. Both parties confirm they will work together to ensure that the site will be comprehensively developed.

Draft Policy LP4 sets out on-site and off-site infrastructure expected to be provided, consider that the provision of such infrastructure will ensure that impacts are mitigated. From a delivery perspective with regard to the Community Infrastructure Levy Regulations, infrastructure contributions secured by planning obligation should not duplicate matters already catered for by the Regulation 123 list.

The draft Policy requires off-site in-kind provision or financial contribution towards a multi-functional community hub. The draft Infrastructure Delivery Plan (2017) indicates it is likely to be the hub constructed at Transport Research Laboratory to the south of the site. However, depending on the scale, location, components and timing of the TRL hub, it is possible that the on-site community hub

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within the draft allocation may be preferable, and therefore suggest the policy is reworded to allow for both scenarios.

Population data underpinning the governments standard housing methodology demonstrates Bracknell Forest is expected to see a steep rise in the number of people agreed 65 and over. Given the housing need figure for the Borough does not include the projected increase in people requiring registered care, suspect the need for bed spaces in use C3 will be greater than the predicted 318 spaces over the plan period. Therefore, consider that Policy LP4 should allow for a C2 facility to be incorporated within the site, should a need be demonstrated.

High quality park homes also offer the opportunity to provide permanent residential accommodation for older people. Given the existence of properties adjoining the site (application 18/00015/CLPUD in March 2018 confirmed lawfulness of two hectares of land within The Hideout for stationing of caravans for leisure/holiday purposes), the policy should be reworded to allow the possibility for some accommodation of this type to be provided as part of the overall development.

Terence O’Rourke for Tingdene Para. 3.138 of the draft sustainability appraisal identifies the risk of Developments Ltd (ID377, 378), grown water emergence in conjunction with surface water flood risk Bracknell Land Ltd (ID397) at The Hideout and Beaufort Park, and this underpins the negative

score that eth site has received in the sustainability appraisal in relation to climate change adaptation. However, para. 3.138 recognises that further technical investigation is required. Given the potential significance of this issue, wish to discuss the work that is required with the Council as soon as possible.

(also summarised under evidence base: Sustainability Appraisal) Boyer Planning for JPP Land/Hodge Developments (ID799-801)

On behalf of owners of Beaufort park site (3.36ha).

Support inclusion of the site from residential development (570 inc 200 affordable), and the revised settlement boundary for Bracknell (as shown on Figs. 7 & 9 of the draft Plan). Site is appropriate for housing, as relatively unconstrained (not within Green Belt, flood risk or area of high landscape character). Is located adjacent to existing residential development and associated recreational facilities, and in an area of future housing growth (1,000 homes at Buckler’s Park). Site is well located for access to the strategic road network and relatively close to a wide range of employment, retail, leisure and other facilities in Bracknell town centre.

The proposed draft allocation excludes the vacant offices building in the control of JPP Land/Hodge Developments, which is supported, and welcome the recognition in the Plan that the site is subject to a separate proposal for residential development.

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Welcomes the recognition of infrastructure improvements within the Policy, but suggest that until the package of infrastructure improvements are known, some flexibility should be incorporated into the Draft Policy, and suggest the following amendment:

“The infrastructure required to support this development may include…”

Para. 6.34 states it is envisaged housing could be delivered in 2027/2028, JPP Land/Hodge Developments suggest there should be no restriction on when homes can come forward on the sites.

Support the guidance provided by the draft concept plan accompanying draft Policy LP4, and welcomes the recognition that the final layout be influenced amongst other matters by a project level Habitats Regulations Assessment.

Pegasus Group for Rumsey (ID 1449)

Site is subject to significant constraints. BRA3 and BRA4 both have 93% of the site at risk of groundwater flooding. The western parcel is almost entirely designated as land of a moderate level of ecological constraint, whilst the eastern parcel (BRA 4) includes a substantial area of high ecological constraint. Substantial areas of woodland will be removed if the land is developed, the deciduous areas of which are recognised as having a high landscape sensitivity.

Principle of development at the site is not resisted. Indicative layout at Map 4, gives insufficient consideration to constraints and extends the areas for development beyond what will realistically be achieved after once proper assessment.

Proposed Change

Recommended, that to provide a more realistic figure for delivery at the site, the capacity is reduced to 400 dwellings.


Paragraphs 6.27 to 6.32 This site is subject to significant constraints. The allocation is made up of two parcels (BRA3 and BRA4). Both parcels are recognised as having 93% of the site at risk of groundwater flooding. The western parcel is almost entirely designated as land of a moderate level of ecological constraint, whilst the eastern parcel (BRA 4) includes a substantial area of land defined as having a high level of ecological constraint. Substantial areas of woodland will be removed if the land is developed, the deciduous areas of which are recognised as having a high landscape sensitivity.

Whilst the principle of development at the site is not resisted, the indicative layout shown at Map 4, appears to give insufficient consideration to such constraints and extends the appropriate areas for development beyond those which will realistically be achieved once proper assessment is undertaken.

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It is therefore recommended, that in order to provide a more realistic figure for eventual delivery at the site, the capacity is reduced from 570 to 400 dwellings.


(Also summarised in evidence base)

In relation the SA, this has been assessed in two parts, whereas other sites such as Hayley Green have been assessed in a single entirety, which is considered to have artificially resulted in the site appearing more sustainable than if assessed as a whole. There is no clear justification for splitting the site.

Detailed comments made on the SA scoring: • Biodiversity (SA3)

Does not take account of the potential to impact on protected specifies. In the Council’s Phase 1 Habitat Survey, Beaufort Park includes breeding site of the woodlark, no mitigation has been put forward, which should result in a negative score. Significant woodland cover would be lost, which should be reflected in the scoring.

• Landscape (SA4a). Scores negatively, however the landscape sensitivity appraisal indicated the cluster scores medium to high. As the sites will be allocated as a single site, cluster scores would be more appropriate, -3 overall.

• Economy and employment (SA9) Council’s SA assessment of BRA3 indicates a score of -1. However, development of the site would not result in any direct gain or loss for the economy or employment in terms of longer term land use. This site should therefore be scored 0 in line with SA methodology. Same for BRA4.

• Land Use (SA18) BRA3 adjoins existing development to the east. When the cluster is assessed as a single entity BRA3 should receive the same score as BRA4 (i.e. -1).

• Revised overall SA score In summary, when applying the revised scoring, Cluster 3 receives an overall SA rating of -8.

The Housing Background Paper identifies a high pressure gas pipeline as a constraints, but this is not considered in the SA. This could affect the developable area. At present, it is not clear what the impact might be in terms of capacity/developability. The SHELAA identifies the site is in multiple ownership, which may restrict comprehensive development. Other site without ownership constraints are availability such as Parkview Farm.

A previous application (15/00826/OUT) for the Hideout element of the site was refused in late 2015 for 112 dwellings and other uses by the Council on a number of grounds.

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Housing Background Paper (page 163) refers to overall landscape sensitivity of medium-high, loss of strategic gap and a number of valued landscape features. Large areas of the site are covered by trees. (ref. Landscape Sensitivity Appraisal of Potential Housing and Employment Sites in Bracknell Forest Borough, 2018), and also supports ecologically important habitats (ref. Phase 1 Ecological Survey, Wenman, September 2017). There are also areas at risk of ground water flooding. The site is also in multiple ownership, which could affect land assembly and delivery. Therefore question the suitability and deliverability of the site.

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Responses to Section: 6.4/Policy LP5. Land south of London Road, east of Bog Lane and west of Swinley Road (Whitmoor Forest), Bracknell

Responses to Section: 6.4/Policy LP5. Land south of London Road, east of Bog Laneand west of Swinley Road (Whitmoor Forest), Bracknell




Natural England (ID115) The site is in close proximity to Englemere Pond SSSI. Ecological assessments should be undertaken for this site to ascertain any direct or indirect impacts on the SSSI, with these impacts being avoided or mitigated for where necessary.

Recommends that the Policy is amended to include wording to ensure the provision of Sustainable Drainage Systems (SuDS).

Binfield Parish Council (ID256) The development looks to be reasonably sympathetic and maintains a good area of woodland. It is not ancient woodland and has more limited value as a natural habitat.



Warfield Parish Council (ID672) Concerned about limited access points for vehicles within proposal. Education & Skills Funding Agency (ESFA) (ID817)

Supports the proposed allocation and safeguarding of land for schools within the Policy.


Noted.


Based on the information currently available, do not support the proposal.

Questions the legality of using Crown Land for housing development.

No detail of the type of proposed housing; requests there would be entry level homes for rent and sale that are not transferred under licence to another area.

No indication of proposed additional on-site employment. Requests provision for small start-up professional businesses.

No detailed information about the retail, leisure and other commercial facilities to be developed

Requests further detail on measures to mitigate impact on roads and encourage sustainable modes of transport. Parking provision at Martin’s Heron Station should be increased to 250+spaces, to meet requirements of the local and wider population, and prevent surrounding roads being used for street parking, as development in Bracknell Forest will bring further commuter traffic to this station.

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Proposed access on the roundabout opposite Brockenhurst Road is not a sensible option, as incidents on the A329 cause congestion along New Forest Ride and encourage the use of residential routes, which causing gridlocking. A more suitable access would be the Whitton Road roundabout, giving direct access to the railway station and superstore. Note that there are three proposed options for access.

Expected a cycleway and footpath giving direct access to the station and superstore.

Public transport connectivity to the railway station is inadequate, and the proposed reduction of services from Martin’s Heron station is in conflict with the rail operator’s statement that there would be more frequent services.

Proposals for a carpark adjacent to New Forest Ride and Wareham Road including the access to the SANG are unsuitable and will have a detrimental impact on local residents. If the car parking were moved to the roundabout opposite Savernake Way this would have the least impact.

There is no mention of routing a bus service to support this development.

Drainage issues are going to be an issue. There would need to be robust evidence that waste water and flood risk would not be problematic.

Martin’s Heron and The Warren residents that back onto New Forest Ride suffer from road traffic noise. This has increased since the installation of traffic signals on the A322. It is likely that this will worsen with the completion of the traffic signals at Mercedes roundabout and any future development exiting directly onto New Forest Ride.

Requests a waste/recycling management plan on this site with proper provision for the free movement of refuse vehicles to undertake collections.

Not convinced that the traffic modelling for this site is correct and the local road network could adequately cope.

Sceptical that the requirement of an ‘On-site in-kind provision of a Primary School’ indicates that there are plans for a ‘creep’ in numbers in future years, thus asking the community to accept more housing but giving nothing in return.

Winkfield Parish does not have a secondary school which results in students having to travel, and they often do not secure a place at their preferred choice of school. A strategic view must be taken to

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address the full range of educational provision in an expanding community, and reduce rush-hour periods.

Proposed development falls below the threshold to provide on-site infrastructure such as a community hub, recreation, and sports fields; the parish is in need of open space with football pitches with adequate car parking arrangements.

No GP surgery within Parish boundaries.

Nothing within the proposals that would glue a community together.

No significant green buffer incorporating existing mature trees, vegetation and ground cover is shown between the proposed housing and New Forest Ride. This is a policy in the emerging Winkfield Neighbourhood Development Plan and essential to prevent the merging of new and existing development.

Development should form a separate settlement, with smaller separate areas with their own individual character and identity.

Development should retain the natural and historic environment including landscape as the area was part of Windsor Forest.

Difficult to give an informed view of site as the three areas suggested for housing do not identify the number of units within each area.

Would be sensible to begin conversing with Lapland, as it is an attraction and asset to the Parish and wider area. Relocate Lapland to a suitable site within the local area if necessary.



Margetts (ID1), Buffet (ID17, 28- Erosion of long-established green corridor/natural habitat which 43), Lief (ID122), Ayres (ID158), separates Ascot/Bracknell, reduction of strategic gap (also when Nixley (ID554), Hawkes (ID taking account of other planned developments, such as Westward 885), Morgan (ID790), Society House, and Lavender Park Golf Club), including being contrary to for the Protection of Ascot proposed Local Plan Policy LP12 (landscape character and strategic (ID805), Browne (ID1580), gaps). Browne (ID1308) Wing (ID16), Elliot (ID22-27), Disregard for/loss of Green Belt. Lief (ID122), Nixley (ID554), Dudley (ID605), Browne (ID1580), Browne (ID1308) Singleton (ID63/92) Loss of Local Gap (as identified in the Entec 2006 study, and

referred to in the Core Strategy Inspector’s report), resulting in coalescence of Bracknell and Ascot. (Comments also refer to WINK

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20 (former landfill site), Palm Hills Estate and The Brackens). Lief (ID122) Proposal will be contrary to Core Strategy Policy CS9 (development

on land outside of settlements). Valli (ID300), Dudley (ID605), Morgan (ID790), Ward (ID1253)

Erosion of countryside.

Overd (ID512) Merging of Ascot with Bracknell and loss of identify as an individual area.

CHARACTER

Cook (ID7), Fletcher (ID10), Bradley (ID13), Hayton (ID14), Elliot (ID22-27), Lynch (ID756), Hawkes (ID885), Menon (ID1536)

Loss of green/open space/greenfield site.

Cousins (ID939) Loss of area that serves a remote, natural role unlike more formal recreational areas e.g. Englemere Pond.

Wing (ID16), Elliot (ID22-27), Jones, M (ID1012), Byles (ID1246)

Loss of woodland/historic forest, which defines the area and is important to the character of the parish.

Detrimental to character of area which will become urban/suburban. Paige (ID366) Area of land adjacent to London Road seems appropriate for

housing, but not the bog behind The Brackens. Synge (ID453) Map seems to show relatively low density and fairly high proportion

of woodland – largely in favour of development going ahead subject to comments on traffic, and proposed car park (see below).

Elliott (ID466) Increase the landscape buffer along New Forest Ride to improve the aspect for Martins Heron residents.

Morgan (ID790) Detrimental to visual amenities of immediate and surrounding area.

HOUSING

Theobold (ID130) Too many houses being built in the area. Chavey Down Residents Association (ID456)

Insufficient detail on the type of proposed housing.

Bollen (ID468), Dudley (ID605) Will building housing in this area still be affordable to new home owners? Insufficient number of affordable homes and self build opportunities.

Dudley (ID605) Need bungalows for sale and rent for older people. Angelova (ID862) The provision of affordable housing within the new development will

have a negative impact on the area. Jennings (ID1173) Area should be developed and extended to include land south of

railway line to Kings Ride.


Margetts (ID1), Fletcher (ID10), Hayton (ID14), Buffet (ID17, 28-43), Ball (ID58), Brown (ID88),

Inappropriate as a biodiverse area (mix of flora and fauna and bogland sections), impact to wildlife (such as deer (muntjac, roe), foxes, hedgehogs, mice, snakes, squirrels, spiders, tree creepers,

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Lief (ID122), Ayres (ID158), red kites, buzzards, owls, woodpeckers, robins, tits, jays, dartford Crawley (ID318), Paige (ID366), warbler, nightjar, woodlark)/loss of biodiversity/local habitat (c. Kirkby (ID530), Nixley (ID554), 46ha), over 100 different specifies of flora and fauna present on the Dudley (ID605), Elsow (ID724), site, should be conserved. Important wildlife corridor. Contrary to Cousins (ID939), Angelova para. 118 of NPPF. (ID862), Wallen (ID824), Morgan (ID790), Warfield Environment Group (ID 1191), Byles (ID1246), Watkins (ID1297) Norton (ID1231) Site involves a rare ‘Lowland Valley Bog’. Remnant of the East-West

bog that came into existence at the end of the last glaciation. It is one of the sources of the River Bullbrook. The sphagnum bog provides a biodiverse habitat and ameliorates flooding. Methane is present. Newts, lizards, black smooth snake, green snake, crossbills and deer have been seen on site. Amelanchier ovalis are present. A scientific survey is required before there is any more degradation.

Margetts (ID1), Buffet (ID28-43),

Given the recent planning permission granted to build on the Kingswood site (East of Swinley Road, south of the railway line), it would create a pinch point/reduced green corridor – no link between the two green areas either side of the railway line/Swinley Road, including being contrary to proposed Local Plan Policy LP38 (green infrastructure).

Hayton (ID14), Lief (ID122), Dudley (ID605)

Loss of Crown Land, including legality.

Hayton (ID14), Buffet (ID17, 28-43), Lief (ID122), Paige (ID366)

Site is within a Site of Special Scientific Interest.

Hayton (ID14), Buffet (ID17, 28- Site lies within the 5km buffer zones to the Thames Basin Heaths 43), Smith (ID20), Lief (ID122), SPA/impact upon the SPA. Jones (ID144), Lynch (ID756), Jones, M (ID1012), Morgan (ID790) Morgan (ID790) Conflicts with Council’s Thames Basic Heaths SPA Supplementary

Planning Document 2018. Jones, M (ID1012), Morgan (ID790)

Impact of pollution from additional traffic on roads within 200m of the SPA and SAC.

Morgan (ID790) Contrary to existing Local Plan policies e.g. BFBLP EN1, EN8, EN20, Core Strategy CS9

Buffet (ID28-43), Saint (ID654), Morgan (ID790)

Proposed site would be contrary to policies in the draft Plan relating to environmental issues: LP11 (protection of the countryside), as the site is currently in the countryside so does not qualify against the 8 categories listed. LP37 (designated nature conservation and geological sites), whilst the sensitivity of development around the SPA /SSSI to t he site is recognised, the development is so close it could contravene the policy statement. LP39 (Thames Basins Heaths Special Protection Area), the proposal will contravene the policy unless sufficient SANG/SAMM mitigation measures are put in place.

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Ball (ID58) Loss of habitat for wildlife (flowering rhododendrons, gorse and heather), important for pollinators.

Singleton (ID63/92) Development of the site would ignore the Habitat of Principle Importance as identified in the NERC Act Section 4.1.

Brown (ID88) Development of the site will lead to loss of connectivity between Swinley Forest SPA and Englemere Pond SSSI.

Hawkes (ID885) Concerned about cumulative impact of new housing being built and planned on Englemere Pond SSSI.

Brown (ID88), Lief (ID122), Morgan (ID790), Watkins (ID1297)

Council should be protecting woodland as a priority/object to loss of woodland. Current proposals on the draft NPPF includes defined reasons for restricting development includes, aged or veteran trees, not just ancient woodland. Also concerned about relationship of development and tree roots.

Morgan (ID790) Conflicts with Bracknell Forest Tree Strategy. Elliot (ID22-27), Lynch (ID756) Clearing of the forest would be contrary to the key constraints

outlined in section 2.19 of the plan in relation to protection of Green Belt, Tree Preservation Orders, and increased flooding. Also contrary to para 4.5 – environmental aspects of sustainable development.

Jones (ID144) What studies have been undertaken to understand the impact of development on local wildlife/what measures are going to be taken to ensure that biodiversity is maintained?

Ayres (ID158) Risk of pollution runoff from housing estate into Englemere Pond (SSSI).


Draining the land for housing will have a detrimental effect upon the delicate bogland of surrounding areas.


Needs to be a green route connectivity from Martins Heron to Englemere Pond and Swinley Park.


Built footprint will encroach into green space cutting off the area from its surrounding environment, reducing the green corridor (north to south).

Overd ID512), Kirkby (ID530) Site is rich in biodiversity and supports/links to Englemere Pond. Elsow (ID724), Cousins (ID939) The value of the undeveloped areas (such as woodland) within the

site would be reduced by the surrounding housing. Housing would result in disturbance, fragmentation, degradation and ultimately disappearance of value of undeveloped areas within development.

Lynch (ID756) If development is allowed, there needs to be a sufficient landscape buffer of trees between New Forest Ride and the development to screen it from Martins Heron residents.

Morgan (ID790) Constraints and Sites exhibition board failed to show location of Swinley Park and Brick Pits SSSI, which is a significant constraints to development and the provision of SANG. Constructing a car park and providing a SANG would have a detrimental impact on it.

BBOWT (ID1215-1219) We have significant concerns about this proposed housing site allocation for approximately 450 houses adjacent to Englemere Pond SSSI. We note that Policy LP5 states in relation to housing density that “the total final number to be subject to further work on the implications of flood and ecological avoidance and mitigation”,

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and that paragraph 6.39 states that “extensive investigation and preparatory works will be required due to flooding and biodiversity issues”, but we have serious concerns that the strategic allocation of this site in the absence of satisfactory information regarding its sustainability as a development site, is contrary to the NPPF (paragraph 165) which states that planning decisions should be based on up-to-date information about the natural environment, and (paragraph 17) that all allocations of land for development should prefer land of lesser environmental value, and (paragraph 118) that if significant harm resulting from a development cannot be avoided (through locating on an alternative site with less harmful impacts), adequately mitigated for, or, as a last resort, compensated for, then planning permission should be refused.


Fletcher (ID10) Is it feasible to place school next to bog/sewage works? Hayton (ID14), Chave (ID15), Increased pollution (noise and air quality, light pollution), (including Wing (ID16), Elliot (ID22-27), during the construction timeframe). What measures will be taken to Ball (ID58), Lief (ID122), Jones reduce the impact? Impact of air pollution on health (asthma). (ID144), Cooper (ID175), Elliott (ID466), Dudley (ID605), Lynch (ID756), Angelova (ID862), Morgan (ID790), Watkins (ID1297), Munns (ID1299) Chave (ID15) Potential for fly tipping if Bog Lane is opened up, how would this be

prevented? Buffet (ID17, 28-43), Crawley Flood risk (including from increased risks from climate change), the (ID318), Paige (ID366), Overd site contains a number of streams/bog area. Implications for new (ID512), Kirkby (ID530), Dudley development and surrounding area - knock on effects of diverting (ID605), Saint (ID654), Lynch water to adjacent areas, and would be contrary to proposed policies (ID756), Jones, M (ID1012), LP40 (flood risk) and LP41 (sustainable drainage systems). Also Cousins (ID939), Hawkes (ID contrary to para 100 and 102 of NPPF. 885), Morgan (ID790), Warfield Environment Group (ID 1191), Browne (ID 1304) Ball (ID58), Lief (ID122) Trees and woodland play an important role in retaining good air

quality. Bracknell Friends of the Earth (ID1355)

If developed, all new homes should be built to the highest standards – insulation, solar panels.

Ball (ID58), Wallen (ID824), Warfield Environment Group (ID 1191)

Impact to future and existing residents, odour from sewage works (will get worse if trees are removed).

Brown (ID88), Ayres (ID158) Increased groundwater flood risk problems, increasing flood risk elsewhere/reduction in natural flood mitigation.

Lief (ID122) Loss of natural drainage provided by the forest. Chavey Down Residents Association (ID456), Wallen

Being on a bog, drainage will be insufficient, and proposal will not be able to mitigate floodrisk (waterlogging and surface water impacts at

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(ID824) Martins Heron).

TRANSPORT

Cook (ID7), Fletcher (ID10), Traffic congestion/increased traffic (roads referred to in Bradley (ID13), Hayton (ID14), representations include: London Road, Swinley Road, traffic cutting Wing (ID16), Buffet (ID17, 28- through from A322 through Martins Heron to Ascot, New Forest 43), Smith (ID20), Elliot (ID22- Ride, combined impact with existing school drop offs, and combined 27), Lief (ID122), Jones impact with housing being built nearby and planned in RBWM). (ID144), Ayres (ID158), Cooper Junctions also referred to (New Forest Ride/London Road). (ID175), Valli (ID300), Chavey Reference also made to Planning Inspectorate’s Appeal Decision Down Residents Association APP/R0335/W/17/3177088 26.02.18 (Land south of Foxley Lane, (ID456), Elliott (ID466), Nixley Binfield, Berkshire) in terms of air quality concerns. Lapland is (ID554), Dudley (ID605), Saint quoted as an example of how there is gridlock when further traffic is (ID654), Lynch (ID756), added to the road system. Angelova (ID862), Morgan (ID790), Society for the A total redesign of the road system and the building of new road Protection of Ascot (ID806), infrastructure would be required for this scale of development. Watkins (ID1297), Munns (ID1299), Browne (ID1580), Browne (ID 1306), Byles (ID1246), Bracknell Friends of the Earth (ID1355) Cook (ID7), Bradley (ID13), Buffet (ID17, 28-43), Browne (ID 1304), Browne (ID 1306)

SW train service already only has standing room at peak time/station does not have capacity. South Western Railway plan to reduce the number of trains stopping at Martin’s Heron.

Cook (ID7), Cooper (ID175), Existing areas within Martins Heron are already used for commuter Valli (ID300), Dudley (ID605), parking. Lack of parking at station. More parking for the station Browne (ID 1304), Browne (ID should be provided on this site. 1306) , Menon (ID1536) Chave (ID15), Hanford (ID111), Safety issues for users of Bog Lane (narrow lane/one vehicle wide) if Morgan (ID790), this is opened up (comments refer to the following users: families,

dog walkers, joggers, ramblers, cyclists etc), including speeding traffic (how would any speed limit be enforced?).

Chave (ID15), Handford (111), If Bog Lane is opened up, although car park may be provided for the Morgan (ID790) SANG, what will stop people parking elsewhere when the car park is

full, or people using parking to access Martins Heron train station. The presence of a car park will encourage the use of cars.

Morgan (ID790) SANG car park and increasing access to the forest will encourage anti social behaviour, litter and unauthorised encampments.

Dudley (ID605) Proposed location and access to SANG car park is unsuitable. Chave (ID15) An existing car park on the B3017 would be a more suitable location

for the SANG (not secluded, no nearby properties, could accommodate additional parking and safety concerns, such as a traffic light crossing over the railway bridge).

Buffet (ID17), Elliot (ID22-27), Proposed site exit onto New Forest Ride will cause chaos, and Dudley (ID605), Lynch (ID756) encourage more rat running through Martins Heron (Setley

Way/Brockenhurst), which will require additional traffic calming measures. Increased gridlock at peak times (also taking account of

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new primary school at this access point). The scheme involving the removal of the roundabout on London Road has not yet been tested and this will add to the gridlock.

Buffet (ID17, 28-43) Proposed access onto Swinley Road is not classed as a vehicle exit in the plan, so how will access be achieved to the eastern side of the development?

Elliott (ID22-27), Lynch (ID756). Friends of the Earth (ID1355)

To support the objective of reduced transport, consider cycle and footpaths from the development for access to Tesco and the railway station, instead of a vehicle access at Brockenhurst roundabout and other areas.

Elliott (ID22-27), Lynch (ID756) If development is authorised, it is very important that construction traffic does not have a vehicular access at New Forest Ride/Brockenhurst Road roundabout – issues of congestion and mud on roads need to be considered through the planning process.

Buffet (ID2843) Proposed site would be contrary to policies in the draft Plan relating to transport and infrastructure issues: LP18 (design), LP45 (strategic transport principles), LP46 (assessing, minimising and mitigating transport impacts of development), LP47 (transport infrastructure provision), and LP48 (travel plans), as there will be unacceptable congestion, roads cannot be expanded, rush hour trains are being reduced by the train operator, it is not within the gift of the Council to improve rail infrastructure. LP1 (sustainability), LP9 (infrastructure), LP10 (presumption in favour of sustainable development).

Singleton (ID64) Proposals (including projects in two Boroughs) will impact the A329 London Road and add more than 200 extra car, how will this be dealt with? (Reference made to the following development proposals: Berkeley Homes at Sunningdale Park; Ascot Centre, Heatherwood Hospital, Former Landfill Site, London Road, Palm Hills Estate, Whitmoor Bog, and The Brackens).

Handford (ID111) Will there be pedestrian crossing points provided along Bog Lane? Jones (ID144), Bracknell Friends of the Earth (ID1355)

Various questions relating to what measures will be taken to: ensure local roads can cope with additional traffic in peak hours; provide for pedestrian crossings (London Road/New Forest Ride); prevent parents parking at Martin’s Heron and walking to/from school; prevent Brockenhurst Road/Setley Way from becoming rat runs.


Consideration should be given to upgrading the railway bridge for road traffic and pedestrians on Swinley Road.

Synge (ID453) Consideration should be given to additional traffic from proposed school, particularly during drop-off/pick-up, this should not block New Forest Ride (which is already heavily congested).

Synge (ID453) If a car park is required, it should be built north, not south of the railway line.

Chavey Down Residents Association (ID456), Bracknell Friends of the Earth (ID1355)

Increase pressure for parking and rail service at Martins Heron Station (already limited parking).

Elliott (ID466) Disruption during construction on local roads (especially at vehicle access point at Brockenhurst Road roundabout).

Dudley (ID605), Morgan (ID790) Unrealistic to assume that new residents will walk/cycle to Martins Heron Railway Station (especially as no cycleway/footpath indicated)

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or other destinations, plus proposals to reduce number of trains stopping at Martins Heron. Reference is made to Planning Inspectorate’s Appeal Decision APP/R0335/W/17/3177088 26.02.18 (Land south of Foxley Lane, Binfield, Berkshire).

Browne (ID 1304), Browne (ID 1306)

good cycle paths within the borough, there is nothing within Winkfield and the roads are too dangerous for many cyclists. Forest Road is a particular example.

Dudley (ID605), Browne (ID 1304), Browne (ID 1306)

No reference to bus service. Existing services are inadequate – have been reduced over the years.

Morgan (ID790) Access to Sewage Treatment Works is in constant use 6and is meant to be a “no parking” area.

Browne (ID 1304), (ID 1306) No information to support statement that there would be 'a comprehensive package of on and off site transport measures to mitigate the impact on roads and encourage sustainable modes of transport’.

INFRASTRUCTURE

Cook (ID7), Hayton (ID14), Wing (ID16), Buffet (ID17), Theobold (ID130), Cooper (ID175), Valli (ID300), Chavey Down Residents Association (ID456), Bollen (ID468), Dudley (ID605), Saint (ID654), Morgan (ID790), Ward (ID 1253), Browne (ID 1304), Browne (ID 1306), Menon (ID1536)

Existing infrastructure/telecoms provisions will not meet capacity/pressure on existing infrastructure (including doctors, dentists/general health care (Heatherwood Hospital), secondary school provision, sports facilities). Reference made to Planning Inspectorate’s Appeal Decision APP/R0335/W/17/3177088 26.02.18 (Land south of Foxley Lane, Binfield, Berkshire).

Fletcher (ID10) New developments and schools not required - already new housing developments.

Fletcher (ID10), Hayton (ID14), Ball (ID58), Brown (ID88), Byles (ID1246)

Loss of recreational space/walking area for local residents.

Buffet (ID17), Bracknell Forest Society (ID164), Bollen (ID468), Saint (ID654)

Whilst a new primary school would mitigate some of the associated education demand, it will not alleviate pressure of additional households on secondary school places.

Dudley (ID605), Morgan (ID 790), Bracknell Friends of the Earth (ID1355)

Further strain on water supply in an area of serious water stress as referred to in BFC IDP and SE Water leaflet.

Dudley (ID605), Browne (ID1580), Browne (ID1308), Bracknell Friends of the Earth (ID1355)

Adverse impact on sewerage/drainage system – proposals are insufficient. Unacceptable to assess this on site by site basis due to cumulative impact of sites, including small sites over a period of time.

Morgan (ID790) Policy fails to mention all necessary associated off-site supporting development required outside proposed site boundary e.g. location and details of SANG with car park, detail of all transport infrastructure.

Dudley (ID605) No community hub indicated

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Morgan (ID790) Impact on South East Water pipeline and gas pipe.

OTHER MATTERS

Lynch (ID756) Concerned about impact of long term construction project over several years on local community.

Angelova (ID862) Concerned about impact on established community and the well looked after nature of the area.

Chave (ID15) Potential antisocial behaviour if Bog Lane is opened up to general public/traffic (such as congregation of cars).

Wing (ID16) Existing housing areas should be regenerated, and convert existing commercial properties.

Morgan (ID790) Need to take into account constraints due to land ownership at and around the entrance to Bog Lane (including existence of “ransom strip” and restrictive covenants on various sections of land here).

Morgan (ID790) Detrimental to residential amenity of properties backing onto no-through-road Bog Lane (including noise, pollution, loss of visual amenity (trees), light-pollution).

Elliot (ID22-27) The proposal would be contrary to the Vision in relation to quality of life being protected and where possible enhanced, and would also contravene many of the Objectives (Sections 3.1 and 3.2 of the Plan).

Elliott (ID22-27) If development is authorised, a sufficient landscape buffer of trees between New Forest Ride and the development is requested to provide a visual barrier to Martins Heron residents.

Buffet (ID90), Saint (ID654) Account should be had of combined impacts of developments (WINK 20 – former London Road tip, and WINK22 – Whitmoor Forest) , and other existing permissions (including sites in RBWM such as Heatherwood and Ascot) and subsequent changes to those numbers once permission has already been granted (increasing housing numbers, such as Brackens applications to increase original permission by 9%). Development of sites has a significant cumulative impact on local community.

Handford (ID111) How will any future SANG car park be managed/maintained, and who would deal with any nuisance issues at night time.

Handford (ID111) Will local residents have a say in where any car park is positioned along Bog Lane?

Lief (ID122), Dudley (ID605), Morgan (ID790)

Queries the inclusion of the site when it has been previously rejected (publicly consulted on in December 2016), understood it was rejected on the basis of the requirement for an identifiable physical local gap between Winkfield/Bracknell and Ascot and being least sustainable. Plans/policies not changed but applications continue to be resubmitted (labour, resource and cost intensive).

Valli (ID300), Browne (ID1580), Browne (ID1308)

Homes will not be affordable, or requirement will be transferred under licence to other areas within the Borough.

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Overd (ID512) Lapland has been granted annual use on part of the land – loss of the site (and linked visits to Bracknell) will result in visitors going to Legoland and Windsor.

Dudley (ID605) SSSI Swinley Park and Brick Pits which is a constraint was not shown on relevant Exhibition Board

Dudley (ID605) Should be allocating land of lesser environmental value. Dudley (ID605) Queries viability and potential this could have on listed infrastructure.

Too easy for developers to get out of providing infrastructure.. Saint (ID654) Lack of information provided to local residents about such a

significant development prior to the exhibition. Need another meeting with all local residents.

Angelova (ID862), Bracknell Friends of the Earth (ID1355)

Convert unused office blocks in Bracknell to housing rather that building on this site.

Cousins (ID939), Bracknell Friends of the Earth (ID1355)

Should be building taller/narrower buildings thus saving land and the loss of sites like this.

Wallen (ID824) Would it make any difference if this site was not allocated, to the overall housing situation

Wallen (ID824) Typo highlighted at para 6.39: preparation Lynch (ID756) The development of this land would be contrary to the Council’s

‘Vision’ particularly where it refers to protecting and enhancing quality of life. Also contrary to sustainable development principles.

Jennings (ID1174) This area is perfect for development and should be extended south of the railway to King's ride.

Browne (ID 1304), Browne (ID 1306),

Lack of information to comment on due to promoter being the Crown Estate.


Hunter Page Planning for Castleoak (ID52/53)

Comments made of behalf of a specialist company working exclusively within the care sector.

Acknowledged it is proposed to amend the settlement boundary, however seems illogical. Would be appropriate to extent the settlement boundary to include Westwood House and Lodge to the east and north of the proposed boundary, allowing the boundary to be adjacent to the road.

No specific comments about the merits of the proposed site. The proposed allocation and existing Berkeley site would provide for C3 dwellings, Westwood House would provide for C2 uses.

Westwood House site is considered to be suitable and available for assisted living units, which would complement residential development being undertaken to the west and south of the proposed allocation. Castleoak are currently in discussion with DM officers regarding a development of c. 76 assisted living units on the site (use class C2).

Woolf Bond on behalf of Site should be omitted from the local pan:

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Hodson Developments (ID916- • It is not controlled by a developer and is subject to 922), JPP and Neal (ID894), covenants. Not available in the short-term. JPP (ID911), Flavia Estates and • Uncertainty regarding suitability in respect of flood risk and JPP Land Ltd (ID 901), Warfield ecological impact. Landscape Sensitivity Appraisal indicates Park (ID1288) a higher sensitivity due to undeveloped rural character and

its role in preventing coalescence of Bracknell and North Ascot.

• The eastern part of the site is separated from the existing settlement where services and facilities would be available.

Rumsey (ID 1450) Site is subject to considerable drainage constraints. Background Paper advises that 100% of the site is at risk of surface water flooding. Issue will therefore need to be examined in great detail before even the principle of any housing of a significant scale can be justified at the site.

If detailed examination indicates development can occur, consideration should be given to the location of the needed secondary school as part of the allocation. The IDP (page 17) notes that ‘the LEA has indicated that the level of growth planned will require a new secondary school to be provided in the north east of the Borough’.

Being located directly adjacent to the eastern urban edge of Bracknell, the site represents an excellent location for a new secondary school to serve both existing and proposed homes in this part of the Borough, where the demand is predicted. It is understood that initial investigations were made during the previous Local Plan / Core Strategy review regarding the site’s potential to accommodate a secondary school due to its attractive location in this respect. At the time the land was not being promoted for development and as a result, the potential could not be realised. That is no longer the case.

Proposed Change

Recommend that, if the site is appropriate for development in terms of drainage, the Allocation should include a requirement to provide a secondary school. Such a requirement may result in a reduction in the number of homes that can be accommodated at the site. However, such homes can be provided at other sites across the Borough, whereas the options for siting a secondary school will be far more limited.

Pegasus Group for the Whitaker Paragraphs 6.33 to 6.38 Family (ID1498-1507) As is apparent from viewing the site, it is subject to considerable

drainage constraints. This is confirmed by commentary within the Housing Background Paper, which advises that 100% of the site is at risk of surface water flooding. This issue will therefore need to be examined in detail before even the principle of any housing of a significant scale can be justified on this site.

If such detailed examination does indicate that development can

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occur without a detrimental impact upon the flood / drainage capacity of the site and surrounding areas, then consideration should be given to the location of a much needed secondary school as part of the allocation. The Infrastructure Delivery Plan (page 17) notes that ‘the LEA has indicated that the level of growth planned will require a new secondary school to be provided in the north east of the Borough’.

Being located directly adjacent to the eastern urban edge of Bracknell, and close to Martins Heron railway station, the site represents an excellent location for a new secondary school to serve both existing and proposed homes in this part of the Borough. It is therefore recommended that, subject to the site being found to be appropriate for development in terms of drainage constraints, the Allocation should include a requirement to provide a secondary school. Such a requirement may result in a reduction in the number of homes that can be accommodated at the site. However, such homes can be provided at other sites across the Borough, whereas the options for siting a secondary school will be far more limited.

Proposed Change It is therefore recommended that, subject to the site being found to be appropriate for development in terms of drainage constraints, the Allocation should include a requirement to provide a secondary school. Such a requirement may result in a reduction in the number of homes that can be accommodated at the site. However, such homes can be provided at other sites across the Borough, whereas the options for siting a secondary school will be far more limited.

Bewley Homes (ID1475) Site is subject to considerable drainage constraints.as documented in Housing Background Paper. If detailed work indicates that development can occur without a detrimental impact upon the flood/drainage capacity of the site and surrounding areas, then consideration should be given to the location of a secondary school on the site as part of the allocation. As the site is adjacent to the eastern urban edge of Bracknell, the site represents an excellent location for a new secondary school to serve both existing and proposed homes in this part of the Borough, where the demand is predicted.

Proposed Change It is therefore recommended that, subject to the site being found to be appropriate for development in terms of drainage constraints, the Allocation should include a requirement to provide a secondary school. Such a requirement may result in a reduction in the number of homes that can be accommodated at the site. However, such homes can be provided at other sites across the Borough, whereas the options for siting a secondary school will be far more limited.

The Crown Estate (ID1421) Support inclusion of site including site specific policy. Site is suitable for a sustainable urban extension. Meets the requirements of existing and proposed national policy. Sequentially

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preferable to sites in the Green Belt.

Wish to deliver new homes (incl affordable housing), primary school, local centre, sports pitches, SANG and POS. Intend to retain ecological habitat and deciduous trees outside managed forestry area. Pedestrian and cycle access to Martins Heron and Bracknell. Vehicular access from London Road, Swinley Road and New Forest Ride. Anticipated that at least 450 homes could be accommodated.

Technical work that has been undertaken to confirm the deliverability of the site – see the following reports:

• Archaeological Desk Based Assessment; • Preliminary Contaminated Land Risk Assessment Report; • Preliminary Ecological Appraisal Summary; • High Level Sustainable Urban Drainage Systems Strategy; • Groundwater Monitoring Interim Technical Note; • Landscape and Visual Appraisal; • Noise and Vibration Report; • Outline Access and Transport Strategy; • Arboricultural Report; and • Utilities Assessment.

LVA confirms that a gap between Bracknell and Ascot can be retained following development. Furthermore, Green Belt to the east will help protect gap.

450 dwellings (as set out in policy) should not be considered as a cap on the amount of development that could come forward on the site - all allocated sites should maximise the amount of housing.

Preliminary Ecology Appraisal of the site has confirmed that the site is not subject to any specific ecological designations, although it is within the 400m – 5km impact zone of the SPA. The site also includes a number of habitats of raised ecological value - do not act as a barrier to the site delivering at least 450 new homes. Suitable mitigation and enhancement measures will de identified and agreed.

Site has high groundwater levels. On-site monitoring of ground water has been undertaken and has informed a preliminary SuDS solution that will be incorporated into the final masterplan for the site. The preliminary solution can be accommodated on the site alongside at least 450 new homes.

Confirm that a 1 form entry primary school can be provided on-site. Envisaged that for a scheme of 450 dwellings, a new community hub should be provided on-site - this would be located alongside the new primary school. Do not envisage there being any requirement for financial contributions towards a multi-functional community hub off-site

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Adequate vehicular access can be provided into the site. There is the potential to utilise access options from London Road, New Forest Ride or Swinley Road. A comprehensive package of on and off-site transport measures will be proposed.

Have commenced discussions with Natural England re SANG - the required amount will be provided on site. Supports reference in Policy LP5 to off-site solution being only one possible solution. SANG areas will be designed to encourage and manage visitor use, whilst enhancing the value of retained and created habitats for wildlife. Associated financial contributions will be made towards Strategic Access Management and Monitoring.

Comprehensive package of Open Space of Public Value (OSPV) will be incorporated into the development proposals for the site. In line with Policy LP50 of the DBFLP.

Although the housing trajectory set out in the DBFLP predicts that the site will start to deliver housing from 2026/27 onwards, it is anticipated that housing could be delivered much sooner than this – possibly 2021. There should be no barriers to early delivery of the site. A delivery rate of approximately 70 dwellings per annum is expected in the current market. Agree with the supporting text to the allocation that it will take approximately 7 years to complete.

The Crown Estate Act The supporting text for Policy LP5 at paragraph 6.37 refers to The Crown Estate Act 1961. It is suggested that the relevant text in DBFLP paragraph 6.37 is amended to read as follows:

“The land is currently designated under The Crown Estate Act 1961 as forming part of Windsor Forest, but The Crown Estate will arrange for what is currently commercial forestry land to be removed from this designation to enable the release of the land for development. This process has been followed previously, and the fact that the land is currently designated is not therefore a material constraint to its allocation and delivery.”


Does not meet all the criteria in Policy LP1, specifically:

(iii) requires… maintenance of local character and landscapes, (iv) requires… protection of area settings (viii) requires… development locations to reduce travel and (ix) requires… less reliance on car travel.


Constraints on the site include: • Heavily wooded, whilst agree that the loss of plantation

species would not represent a constraint, clearance of extensive woodland may have biodiversity implications. Proximity of the SSSI adds weight to the concerns.

• Railway line. • A high pressure gas pipe line affects the site, but this has not

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been identified as a constraint. • Requirement to provide SANG provision. • The site is not level, so will require extensive regarding works

to facilitate development. • On-site infrastructure such as a school and multi-functional

hub have been identified.

Whilst none of the constraints are outright likely to inhibit the development of this site, there clearly some potential for viability concerns to emerge as an impediment to timely delivery.

The site is currently classified as a Designated Land under the provisions of the Crown Estate Act 1961, and the SHELAA identifies covenants which may impede or delay the delivery.

Overall, it is considered that there a number of uncertainties as to the deliverability and developabilty of proposed allocation LP5.



Detailed comments made on the SA scoring: • Climate Change (SA1)

This score is derived from the overall score measured against the indictors set out in the Transport Accessibility Assessment (2017). There is a difference in scoring between 2010 and 2017 version of the Transport Accessibility Assessment. Circumstances have not changed significantly, therefore no justification for the divergence in scoring (2010: -1.5, compared to 2017 score of 7). It is considered appropriate to apply the 2010 assessment scores, which would indicate the site should score 0 in line with the SA.

• Biodiversity (SA3) Site scores -2, but does not take account of impact upon protected species. , as the site supports populations of Great Crested Newt and Nightjar. Development of the site would impact on biodiversity interest of more than local significance, so would be scored -3.

• Health (SA12) The Council’s SA scores the site as 0 against this objective. However, the site is well related to three areas of significant open space. It is reasonably related to leisure facilities which are largely located within Bracknell. The site is not constrained by any public rights of way nor by traffic congestion. On this basis the site should be assessed as having a score of +2.

• Revised overall SA score This should score -5 instead of the current -2.

The SHELAA indicates there are restrictive covenants on the land. On the basis of the information provided, the extent of the covenant restriction is unclear, and there is no certainty this could be

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overcome, and be developed within the plan period, so it should not be included in the Plan.

The footnote for Policy LP5 set out in the Draft Local Plan indicate that the:

‘Total final number to be subject to further consideration of the impacts on the heritage assets’

At this stage, there is no certainty that the number of dwellings indicated in the Local Plan can be delivered. Alternative /additional sites should therefore be considered to ensure the Council is able to meet its housing need (such as Parkview Farm).


The site is within a strategic gap between Bracknell and North Ascot. The Landscape Sensitivity Appraisal of Potential Housing and Employment Sites in Bracknell Forest Borough (2018), identifies valued landscape features of woodland and remnant heathlands. Phase 1 Ecological Survey (Wenman, September 2017) shows that the site supports several large areas of ecologically important habitat types. The site is located very close to two Sites of Special Scientific Interest (SSSIs): Swinley Park and Brick Pits, and Englemere Pond, so potential impacts on these Nationally important sites will need to be considered.

There is also risk of groundwater flooding. In addition, the Housing Background Paper states (page 272) that the site has not immediately passed the Sequential Test, Level 2 SFRA required.

Proximity to the railway line could also impact the developable area in terms of noise mitigation would be required.

There are also covenants on the site.

In light of the above, do not have assurance the site could be developed.

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Responses to Section: 6.5/Policy LP6. Land at Winkfield Row.





Natural England (ID116) Notes that that there are parcels of land on the southern section of the site which are best and most versatile (BMV) agricultural land (grade 3a). Advise that wording is added to the Policy to ensure that the development considers BMV land appropriately. Agricultural Land Classification (ALC) survey data should be used to assess the loss of land or quality of land, coupled with further soil survey work if appropriate. Further information can be found in Natural England’s Technical Information Note 049.

Binfield Parish Council (ID258) There will be increased traffic flows along Forest Road through Binfield from this development.

Environment Agency (ID1260) Refer to comments on the sequential test in relation to Policy LP3. In addition, cannot be confident with SA findings in relation to the neutral/positive effect against Objective SA1 until sequential test has been properly applied.

Site is at flood risk but there are no requirements in Policy LP6 addressing this. Should the site pass the sequential test, Policy LP6 must refer to need for a FRA and the sequential approach locating all built development in Flood Zone 1. Without this, Policy LP6 would be unsound.

Amend Policy LP6 including need for a technical investigation and assessment of flooding (included in Policies LP4 & LP5 which are not at risk of flooding). Though concept plan shows SANG on land at risk of flooding, Policy LP6 should specifically require all built development to be in Flood Zone 1, which ensures policy reflects Objectives B&D.

Provided site passes the sequential test, impact of climate change can be addressed by providing additional flood storage within the SANG, contributing towards Objectives B&D.



Warfield Parish Council (ID673) Notes the lack of transport infrastructure improvements showing on map 6 compared to other sites.

Education & Skills Funding Agency (ESFA) (ID817)



Noted.

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Unrealistic for interested parties to review a 1200+ page document. Shorter paper, with references to appended detail, should have been made available.

Maps on consultation portal difficult to navigate to see detail or to reference the key at the same time. Fails to meet BFCs obligations to provide clear, concise and easily accessible documents.

The consulting process was inadequate with regard to number of meetings and the communication of meetings. No additional events were arranged for the north of the Parish

Disappointed that BFC did not consult local Resident Associations.

Based on the information currently available, do not support the proposal.

No detail of the type of proposed housing; requests entry level homes for rent and sale are included, and that these would not be transferred under licence to another area.

No indication of proposed additional employment on site. Requests provision for small start-up professional businesses.

No detailed information about the retail, leisure and other commercial facilities to be developed.

Requests more detail on the measures to mitigate the development’s impact on roads and encourage sustainable modes of transport.

No confidence surrounding roads could accommodate development of this scale. Insists it is essential to update traffic modelling when planning the proposed scale of additional housing to ensure the road network can adequately cope, as there are significant congestion hotspots that could worsen.

Unconvinced that the traffic modelling for the crossroads at Forest Road/Braziers Lane/Locks Ride is correct as it currently struggles in the rush hour and is a growing problem. Development plans are likely to result in a dramatic increase in journey times. Proposed junction will need three lanes and there is insufficient space to have three, and Forest Road would require significant improvements along most of the carriageway.

The Traffic Accessibility Assessment, Appendix 1 notes individual sites comprising Cluster 5 have been assessed and are ranked at 2. = no congestion hotspots. There are significant congestion hotspots during peak travel times at the Locks Ride/Forest Road/Braziers Lane junction and also along Forest Road queuing back from the Hatchet Lane junction in North Ascot.

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Cluster 5 does not meet Policy LP1 requirement as the location doesn’t reduce the need to travel and the reliance on private cars will not be minimal.

Contributions should be made to the provision of additional off-road parking at Martin’s Heron station for commuters.

Requests a waste/recycling management plan on site with provision for the free movement of refuse vehicles to undertake collections.

This area is frequently flooded during heavy periods of rain. Flash flooding is very evident within the area which adversely impacts the sewerage system. Require evidence that waste water, flood risk and sewerage would not be of any concern or exacerbate the existing problems. Solutions to the overburdened infrastructure are required.

The proposals are very different from what was originally shown to the Parish Council by the developers. There is very little gain for the local community.

No community hub is planned. This would be essential based on the number of proposed dwellings which should include a neighbourhood retail unit which should be joined to the current facilities. Winkfield is in desperate need of a GP surgery and a secondary school.

No plans for additional sports or leisure facilities shown - the most obvious and acceptable solution would be to add to and enhance the facilities at Locks Ride with a redeveloped Locks Ride Pavilion. Struggles to provide sufficient football pitch availability and associated car parking which causes an overspill of vehicles onto nearby roads.

Sceptical that the requirement of an ‘on-site in-kind provision of a Primary School’ indicates that there are plans for a ‘creep’ in numbers in future years, thus asking the community to take further housing with nothing in return.

Cluster 5 and 7 plans make provision for a school Concerned about the future use of the Winkfield St Mary’s School site should the school close.

The proposed school at Hayley Green, and proposals regarding Ascot Heath Infant and Junior schools, would result in three primary schools within a mile of each other all accessed from the Forest Road, collectively bringing excess traffic. Query the need for the number of additional schools, given the level of new housing proposed.

Query where secondary school need would be provided. Proposed development falls below the threshold to provide on site

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infrastructure such as community facilities. Concerned that no additional open space has been provided adjacent to the existing Locks Ride and Forest Road recreation grounds.

Very little detail provided in relation to climate change mitigation and adaptation, conservation and enhancement of the surrounding landscape.

No significant green buffer incorporating existing mature trees, vegetation and ground cover is shown on the boundaries of the proposed development. This is a policy in the emerging Neighbourhood Development Plan and essential to prevent the merging of the new development with existing developments.

Cluster 5 does not meet policy LP 1 requirement to protect and enhance the natural environment, or enhance and maintain the local character.

Cluster 5 SANG does not appear to meet requirements and would need to be brought up to spec, reducing the overall viability of Cluster 5. 11ha is a relatively small space, with a perimeter less than 2k,and the area is flat and prone to water logging. Therefore it is not possible to provide sufficient mitigation against the negative impact on the Thames Basin Heath.

Difficult to give an informed view of this site as the areas suggested for housing do not identify the number of units within each area.



Ellingham (ID65), Vinson Loss of gap between Bracknell and Ascot/contrary to draft Policy Vinson (ID177, 181, 343, 341) LP12 Williams (ID356) Evans (ID508) Luker (ID594) Van Oeffelen Erosion of strategic gap detracts from communities having their own (ID613) Day (ID759) Bartlett identity and local distinctiveness. Loss of Winkfield Row as a (ID 1497) Maidens Green separate settlement. Society (ID 1154) Dyer (ID166) Browne V (ID 1304) Browne J Cluster 5 sits in the strategic gap between Ascot & Bracknell. (ID 1306) Sustainability Appraisal states that development of the site would

erode the gap. Redefining the gap and countryside to suit development plans makes a mockery of the protection in place.

Infilling of the triangle will erode the rural gap between Winkfield Row South and the conservation area of Winkfield Row South, contrary to clause 11.2.9.

Concern over Coalescence with settlements of Winkfield, Winkfield Row, Hayley Green, & Maidens Green, Carnation Drive

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Murphy (ID627) Concept plan disregards the amenity of the existing settlement, in allocating the vast majority of the green space that surrounds them and they see every day to housing.

Andrews (ID446) There are no clear plans for maintaining the semi-rural green space in the area in a sensitive way. Particularly woodland, and green spaces that are part of the intrinsic nature and beauty of this area.

Griffiths (ID462) This is a beautiful area of countryside that the plan proposes to destroy. It is vital green space to give a buffer to the important and protected Green Belt land and Thames Basin Heath adjacent to the development area.

Gill (ID552) Townsend (ID 864) Mix of forested and open landscapes, and valued countryside will no longer be protected. Unacceptable impact on countryside conservation.

Luker (ID594) Beidas (ID 1224) Concern at lack of green buffer. This should incorporate existing mature trees along Lock Ride / Forest Rd and to prevent merging of settlements.

Lyes (ID797) WRRA (ID 958) Policy LP12 requires development to be sympathetic to landscape character as set out in the Landscape Character Assessment (LCA). Southern Part of Cluster 5 falls within LCA C2. Noted valued characteristics apply to this area and would be threatened by proposed Cluster 5 development:

• Naturalistic land cover • Remnant pastoral fields • Views across small clearings, paddocks and pastures

…..provide a sense of open space and removal from the densely developed surrounding areas

• Long straight roads …. Allowing some longer distance views in a landscape well enclosed in trees (Note - this would apply to Locks Ride)

Northern Part of Cluster 5 falls within LCA F1. Noted valued characteristics apply to this area and would be threatened by development despite lower density proposed for this part of the site:

• Evidence of medieval history – (Note - some of the fields to be allocated as a SANG – this would change the nature of them)

• Rural character …..particularly valued due to the built up nature of much of the borough.

Proposed development sites at Winkfield Row are contrary to BFC’s commitment to protect valued features of the landscape

Infilling of Winkfield Triangle between Locks Ride and Chavey Down Rd would lead to loss of landscape character. Infilling triangle risks eroding rural gap between Winkfield Row N and Winkfield Row S and landscape/ townscape character.

Overdevelopment and infilling of Winkfield Triangle will cause loss of long views to surrounding landscape contrary to Character Assessment SPD. Loss of long views from Locks Ride across Winkfield Triangle is unacceptable since will destroy sense of

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separation and the character of conservation area.

Cumulative landscape impact is happening now, additional development of Cluster 5 land will further exacerbate this problem. Proposed infill of Winkfield Triangle, with high density multiple-storey dwellings, will continue to harm character of existing settlement and open character of Chavey Down Road.

Society for the Protection of Ascot (ID807)

Draft plan says in 4.5 that creating a high quality distinctive built environment should take account of the character of urban and rural landscapes. Winkfield Row is currently a rural environment and defined as such in the current BFC Local Plan. Whilst it could probably take some development and remain substantially rural, the proposal for 500 dwellings will change the site to a predominantly urban/suburban.

CHARACTER

McCulloch (ID2) Disproportionate to the local community (designated GAP and Green Belt). Smaller developments should be considered.

Taylor (ID51/143), Foulkes Scale of development out of keeping with existing hamlets/villages (ID121), Smith (ID134), Dyer (Winkfield), will destroy village nature of the area/rural character. (ID166), Vinson (ID178, 181, Will harm balance between open spaces and housing. Will not 185), Brett (ID201) Horsfield reflect the area’s charm or varied housing stock. Does not follow or (ID355) Kesselman (ID476) complement the existing village footprint. Disproportionate increase Ward (ID517, 518) Gill (ID552) in population. Virgo (ID616) Bennett (ID758) Bartlett (ID 1497) Ellingham (ID65), Cornwell Loss of local unique character/semi rural/rural nature with proposed (ID65), Willshire (ID78); Murphy development (some comments also reference including views from (ID85) Vinson (ID344) St Marys School across Forest Row, impact to Conservation Area – Gorlowski (ID470) Jarvis also see comments under Heritage). Loss of farmland. Loss of rural (ID488) Bollen R (ID507) Overd views. (ID513) Brett (ID516) Dorman (ID589) Day (ID759) n Piper (ID1049) Cornwell (ID67) The Plan should have regard to the Design SPD/Character Areas

SPD which are listed as evidence base, in relation to proposals for Winkfield Row.

Morrow (ID68) Object to loss of green environment (wildlife and natural green areas).

Bartlett (ID 1497) Character homes have been lost and replaced with several out of character new homes on each site

Bruen (ID93) Gill (ID552) Winkfield Row has a distinctly rural feel, development in the northern Luker (ID594) Van Oeffelen part of the village would introduce two urban estates out of keeping (ID316) Murphy (ID 1011) with traditional farms and Victorian dwellings. Clusters 5 and 7 Fazey-Gunn (ID 1238) would have an urbanising impact on Winkfield’s character and

appearance. Rural area would be compromised (ref to Local Character Area F1)’ Impact on character of Winkfield Row / Chavey Down. The number of houses and their location will spoil the rural setting for those living in the area. Reference also to impact of other

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proposed sites. Green (ID95) Recognise the need for housing in the local area, but amount is not

sensitive to the composition of the local area/out of character. Bartlett (ID1497) Any new houses built along from the Locks Ride homes would ruin

the character of the road. Gunn (ID 1158) Site unsuitable for 500 houses. Request to seek alternative sites

and/or reduce the number of houses significantly to suit the area. Foulkes (ID121) Bruen (ID330) Proposal will be contrary to the Plan’s Objectives (identities of

existing settlements are maintained), Sustainable Development Principles (protect and enhance existing assets), Overarching Spatial Strategy (it is important to retain the identity and integrity of these smaller settlements (N of Bracknell), and Winkfield Row Policy (which refers to the setting of Winkfield Row and Chavey Down). Infill building would destroy the unique communities and is contrary to BFC policies regarding community character.

Brett (ID 204, 205, 206, 207) Chavey Down Association (ID 456) Beidas (ID 1224) Browne V (ID 1304) Browne J (ID 1306)

No detail on types of housing to be built, design details not clear.

Luker (ID 594) Proposals are contrary to Policy LP18 Cluster 5 is adjacent to Northern Villages character areas C and D. Proposals do not conform to LP18 due to density and patterns of development. ‘Open Rural Gap’ between North and South Winkfield Row would be lost Area D - linear or ribbon development – an estate as proposed would not comply and would harm this characteristic Area C - high quality character and townscape based on the historical settlement structure – the proposed development would harm this characteristic

Bruen (ID 332, 333) Dorman (ID589) WRRA (ID941, 965) Vinson (ID 341)

Proposed housing density for Winkfield Row and Hayley Green is out of character with the existing village feel. A rough calculation on Winkfield row shows a far higher building density. Density proposed would require town house style development completely out of keeping with the existing. Existing density if around 12-18 dph and proposal would be for 500 homes on 16 hectares = 28 dph. This would give the area a suburban character. Scale of dwellings is out of context with small scale homes at Winkfield Row South.

Vinson (ID 343) Local Plan (para 5.11) states it is important to maintain the identity and integrity of the smaller settlements to the north of Bracknell Town (such as Winkfield and Hayley Green) and refers to smaller scale opportunities for development through infilling and changes of use. The plans for Cluster 5 and Cluster 7 are not “smaller scale opportunities for development through infilling and changes of use”

Vinson (ID344) Ward (ID 1251) Paragraph 6.41 refers to the rural character and high historic landscape value of the Winkfield Row site. The proposed development of this site will have a major detrimental impact on the local rural character.

Williams (ID356) Griffiths (ID462) Gill (ID552)

Site is in a “Character Area” and para 11.2.14 of the draft local plan highlights importance of the Landscape Character Assessment SPD.

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Stolagiewicz (ID556) The plan does not include adequate measures to protect the unique Luker (ID594) Bartlett (ID1497) character of land at Winkfield Row. Infilling of the Winkfield Triangle WRRA (ID 965) Vinson (ID 341) would destroy the ribbon development and traditional street pattern Gaw (ID 1397) leading to loss of “the most significant characteristic” identified in the

Character Assessment SPD. Loss of the linear settlement pattern along Chavey Down Rd and Locks Ride contravenes clause 11.2.1 & BFC’s commitment to protect valued features. Infilling will result in loss of long and glimpsed views to surrounding landscape, which are a feature of the north end of Locks Ride and Forest Rd. Characteristics of naturalistic land cover, remnant pastoral land, views across small clearings and long straight roads would be threatened by proposed development. The Character SPD says redevelopment should NOT lead to loss of connectivity/ glimpses in to open fields. The Plan contradicts BFC’s own commitment to protect important Character and features of the local area. Gaps in the existing streetscene should be minimised.

Griffiths (ID462) Mature trees and hedgerows give the area is charm and character. It is impossible to enhance this ancient landscape with bricks and mortar.

Glover (ID511) Proposal would despoil a whole area, particularly with other developments taking place in surrounding areas.

Stolagiewicz (ID556, 937) Major new estate development would erode traditional linear settlement pattern. Large developments should relate well to the existing street pattern and not harm existing street character; • Redevelopment should not erode the street landscape and the sense of wooded enclosure permeating into the settlement; • Over-development could cause loss of glimpses of fields or woodland, some views into surrounding landscape should be maintained; Any new development should retain the linear settlement pattern.

Luker (ID594) Contrary to Policy LP1 as Cluster 5 fails to enhance and maintain the local character

Taylor (ID661) New homes should have high quality architectural design, be in a variety of styles and be well landscaped/built at low density to preserve rural/village character.

Prior (ID740) Current building in the area is leading to Wokingham and Bracknell being almost joined together. This is likely to creep further across Binfield and Winkfield Row and head North. Existing semi-rural views will be destroyed.

Lyes (ID798) WRRA (ID941, 965)

Proposals conflict with Policy LP18 as cluster 5 site is adjacent to the Northern Villages character areas C& D. The proposals do not conform to LP18 in that the high density level of housing proposed is not in general conformity of areas C&D and does not respect patterns of development: Area C is described as high quality character and townscape based on historic settlement structure. Area D is described as predominately linear development and that

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major new estate development could further erode the traditional linear settlement pattern. The need for new housing is not an acceptable trade-off for harm to the character. Infilling of Winkfield Triangle would depart from traditional street pattern. The Character Assessment open rural gap between Winkfield Row North and South would be lost. Loss of long/glimpsed views, loss of ribbon development.

Day (ID759) BFC has a duty to protect the character of communities in the Borough.

HOUSING

Cornwell (ID67), Gamble (ID142) Dorman (ID589) Skudder (ID501, 664) Wilcock (ID737) Smith (ID886)

Delivery of affordable housing in the Borough as a percentage of dwellings permitted in last 5 years is around 8%. (Comments ask whether there is sufficient evidence in the Local Plan that sites in Winkfield Row are viable and plan for affordable housing as a rate of 35%) If developers do not meet the target the proposals cannot be sustainable or deliverable.

Young (ID72) Object to additional housing in Winkfield Row area. Ward (ID517, 518) Bartlett (ID 1497) Ward (ID 1251)

Affordable housing is not truly affordable and sites deliver less than the policy requirement (8% in recent cases). Council should obtain Crown Land for affordable housing – possibly along Swinley Road. Local residents would reap no benefits from the proposed housing even with ‘affordable’ housing which most young people would find unaffordable.

Luker (ID594) Virgo (ID616) Lyes (ID793) WRRA (ID943) Greenan (ID 1187) Gaw (ID 1390)

Questions viability/delivery of 35% affordable housing (along with other infrastructure)

Prior (ID740) Local houses are expensive, so who will be able to afford more housing in this area?

Browne V (ID 1304) Browne J (ID 1306)

Necessity is for starter homes and affordable housing

Gaw (ID 1390, 1392) Affordable homes need to be where people can easily reach facilities/workplaces. Cluster 5 does not reduce the need to travel.


Murphy (ID85), Bruen (ID93), Dyer (ID166), Evans (ID508) Virgo (ID616)

Concerns regarding impact upon the Winkfield Row and Winkfield Village Conservation Areas if development goes ahead/will not enhance the environment.

Ward (ID517, 518) Proposed 500 homes would harm the historic landscape of the area. Bruen (ID93) Smith (ID886) Concern about the impact upon the setting of Somerton Farm (listed

building) and historic farmland and trees. Bruen (ID93) Reference to any application being accompanied by a Conservation

Management Plan, does one exist? Prior (ID740) Destroying historic open areas to build housing will ruin the

environment. Dyer (ID166), Brett (ID188, 189, 196, 201, 216, 516) Gill (ID552)

Northwest of the cluster has an historic fieldscape unique to the District. SANG and new spine road are likely to have a harmful

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I




Lyes (ID791) WRRA (ID941) impact on this historic fieldscape. Vinson (ID178, 185, 342, 344) Loss of Farmland - harmful effect to heritage (which the Council

admits is unlikely to be mitigated, as the type of heritage is rare – para. 3.189 of the Sustainability Appraisal.

Brett (ID204, 205, 216, 217) Nothing apparent to keep historic beauty of the location/protect the historic environment.

Luker (ID594) Evidence of medieval history would be threatened (ref to Local Character Area F1)

Murphy (ID561) Fears for the beautiful Conservation Area of Winkfield Row, if the proposed development sites go ahead. This conservation area is in the middle of the proposed sites and the impact of up to 1500 plus extra cars using the road network around Winkfield Row daily, is unthinkable.

Skudder (ID501, 664) Concern at the impact of the proposed new Braziers Lane / Forest Rd link road on the an area of high historic landscape sensitivity.

Dorman (ID589) Braziers Lane is a medieval road and there are several landmark historic sites in Cluster 5.

No Reference Cluster site 5 entrance is a short distance from Church Rd. Closing part of Braziers Lane will increase traffic, pushing traffic further down the line onto Church Road A330 T junction, drawing the settlements closer creating further infill areas in the future, with traffic spill into The Winkfield Conservation area, with its fast bends in front of Winkfield St Marys Church Grade II* Listed and The White Hart Pub Grade II listed, The Old Rectory Grade II Listed. As referred in The Winkfield Chronicles researched by local historian Ruth Timbrell.

BFBC must be more aware of this historic part of part of Winkfield and Maidens Green, as English Heritage and Historic England recognise. This Northern part of Winkfield in just a small area has twelve Listed Buildings Plus a further nine non listed properties in Maidens Green worthy of being heritage assets noted in MG character assessment. Indeed Braziers Lane is the boundary to Ascot Place which is Grade II* Listed and also borders Forest Road and Hatchet Lane, Somerton Farm is also a Listed Building.

NATURAL ENVIRONMENT (biodiversity, designated sites, green infrastructure, Thames Basin Heaths Special Protection Area, Landscape)

Collins (ID60/61) The plan presents a balance between the need for housing and local sensitivities, however crucial that the proposed SANGS are transferred to the Council; so they can remain in perpetuity.

Cornwell (ID68), Bruen (ID93), Dyer (ID166)

The SANG will result in existing community with sculptured parks in lieu of existing historic natural woodland/meadows and associated wildlife/concerns that animals using existing field (badgers, foxes, deer etc) will be displaced if turned to a park for human use.

Murphy (ID85, 461), Dyer (ID166)

Fields where SANG and primary school are proposed do not lend themselves to development, wildlife will be devastated/negative impact and affected by construction and light pollution (badgers, owls, deer, bats, hedgehog, cuckoo.

Calcutt (ID89) Proposal will conflict with section 17.1.7 of the Plan (wildlife corridors

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or ecological networks are important for linking habitats and allowing the movement of species across the landscape), in relation to the existing belt of fields between Locks Ride across Forest Road and alongside Winkfield Row village.

Bruen (ID93/94) The SANG area contains ancient hedgerows, which by creating a park will result in their removal, contrary to existing Policies (EN1 and EN2) and proposed Policy LP11.

Prior (ID740) Developed, man-made parks are no substitute for the existing semi-rural footpaths along the edges of fields. Wildlife is a big part of this area, and should be respected.

Smith (ID134), Dorman (ID137, 589) Kesselman (ID476) Jarvis (ID488) Van Oeffelen (ID316) Bennett (ID758) Townsend (ID 864) Gunn (ID 1158) Beidas (ID 1224) Fazey-Gunn (ID 1238)

Impact upon wildlife/hedgerows/trees, loss of habitat (reference to red kite & deer).

Dyer (ID166) Light pollution from the new estates will impact upon wildlife (bats, owls).

Vinson (ID178, 181, 185, 342) Andrews (ID446) Dorman (ID589) Luker (ID594) Lyes (ID792, 794) WRRA (ID941) Browne V (ID 1304) Browne J (ID 1306) Gaw (ID 1390, 1393)

Proposed SANG is small (11Ha), flat and waterlogged, would need work to bring it up to required standard. Would not provide sufficient mitigation of negative impact upon the Thames Basin Heath due to its small size, route choice, lack of attractiveness to walkers and undulating landscape. Flat open fields may not be interesting enough. Cost of improvements could affect overall viability of the proposal. Delivery of NE requirements could affect viability/deliverability of overall scheme.

Brett (ID218, 219) No Plans/insufficient plans to protect the environment. Wilcock (ID737) Proposed SANG area is in a flood zone, the current footpaths are

impossible to walk along in times of wet weather. Eustace (ID 1370) It is essential that Bracknell Forest Council (or similar body) take

over formal possession and management of the SANG. Should it remain in private ownership its delivery will be put at risk and as neighbouring land owners we would be very concerned about its ongoing management.

Saunders (ID299) Griffiths (ID462) Dorman (ID589)

The proposed development is a threat to the environment and local wildlife and cuts important wildlife corridors.

Bruen (ID334) Green spaces in Winkfield Row and Hayley Green will be seriously eroded.

Maidens Green Society (ID 1154)

The SANG – Cluster 5 may seem small at 11 ha or 27 acres but would provide close access to the development for walking, nature environment etc., being preferable to it being used for further housing.

Williams (ID356) A managed area of green space via the provision of a SANG is not an adequate replacement for areas of currently undisturbed private fieldscape and other habitat. The identified area for the SANG is prone to water logging, and flooding, also making it unsuitable for public access.

Skudder (ID501, 664) Proposed new junction between the end of the row of cottages and the existing Somerton Farm would harm a group of large mature oak

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trees inhabited by owls. This would be contrary to BFC policy and not preserve biodiversity.

Bollen (ID506) Proposed changes to the SPA area appear to be made in order to facilitate insensitive and inappropriate development.

Gill (ID552) BFC is proposing to develop the small remaining area that is identified as countryside on the map. The responsibility to biodiversity will not be met.

Luker (ID594) Contrary to Policy LP1 as Cluster 5 fails to protect and enhance and the natural environment.

Skudder (ID501, 664, 663) Increased traffic levels will harm wildlife (reference to 2 incidents vehicles colliding with deer)

Lyes (ID792, 794) WRRA (ID941)

Ecological survey shows that land south of Forest Rd has a 6Ha area of moderate ecological constraint – the loss of this natural habitat is unacceptable.


Taylor (ID51/143) Policies should enable infrastructure to be provided, whilst safeguarding and enhancing the environment and tackling climate change.

Francis (ID55) Griffiths (ID462)

The Cut flows through Winkfield Row close to Lambrook School, which in previous years the combination of surface water and effluent drainage as been deposited on the border of the school.

The proposal will add huge area of impermeable surfaces which will speed up surface water run-off (Roads, drive-ways, Roofing). The small stream, The Cut, which will ultimately carry waste water to the Thames is regularly prone to flooding, so this would create problems on site, and downstream due to flash floods.

This issue must be addressed if a significant number of houses are to be added to the system.

Williams (ID356) Document LP/Ev/4f scores Cluster 5 as +1 in Band 3 among the worst rated sites.

Chavey Down Association (ID456)

This area is frequently flooded including flash flooding which can, and does, adversely impact on the sewerage system. Evidence is needed that waste water, flood risk and sewerage would not be any concern or exacerbate the existing problems. Solutions should be provided to the already overburdened infrastructure. The site backs onto The Cut and is partly within the flood plain. The river and surface water flood risk could be significant on this site and the increased built footprint would make this worse.

Murphy (ID85, 461), Vinson (ID177, 186) Chavey Down Association (ID456) Ward (ID517, 518) Stolagiewicz (ID556, 937) Luker (ID594) Virgo (ID616) Ganachaud

Area already suffers from flooding with heavy rain, and cannot cope with further development (land is primarily clay, drainage during heavy rain in poor) Reference to Para 103 of NPPF and Thames Water RAG Assessment (Red for this area).

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(ID617) Bennett (ID758) Gunn (ID 1158) Fazey-Gunn (ID 1238) Calcutt (ID91) Gill (ID552) Dorman (ID589) Van Oeffelen (ID316) Smith (ID886) Beidas (ID 1224) Browne V (ID 1304) Browne J (ID 1306)

There are a number of local watercourses within the Winkfield Row/Cluster 5 area which currently suffer a degree of flooding (including the junction of Locks Ride/Braziers Lane/Forest Road), unless effectively managed, will result in a greater risk of local flooding. Drainage sewerage system in the area requires a complete overhaul. The proposals for sewerage and drainage are insufficient.

Townsend (ID 864) The area around Forest Road, Locks Ride, Braziers Lane is frequently flooded so will not be suitable for houses. There will be too much run-off and the houses will be built on boggy ground.

Dorman (ID137) Impact to air quality needs to be addressed. Brett (ID150, 188, 189, 196, 199, 200, 216, 516)

Little information relating to water quality, and no concerns identified in relation to Winkfield area in the consultation. Reference made to Water Cycle Study, which states water quality is not sustainable, and the northern river corridor catchment area was a concern in relation to water quality, flooding and pollution from development. What will be done to resolve this now, and with the burden of 500 new homes.

Dyer (ID166) Northern part of the site borders flood zone 2 and 3 – development would be better places on other sites further from water courses.

Vinson (ID177, 186, 341) Van Oeffelen (ID316)

Impact to sewerage system (already under strain).

Vinson (ID186, 347, 341) Evans (ID508)

There is a risk of flooding in Winkfield, and the site did not pass the sequential test assessment (a risk of surface water and groundwater flood risk is referred in the Infrastructure Delivery Plan, and para. 3.169 of the Draft Sustainability Appraisal).

Gill (ID552) Pollution and existing flooding issues will be exacerbated. Brett (ID197, 198, 216, 222, 223, 516)

Road water drainage evidence every winter, ditches to the south of Locks Ride and cross roads are an annual issue. Insufficient plans made in respect of flood problems.

Lyes (ID795) WRRA (ID953) Not clear from this policy how many of the nine sustainability principles should be met for development to be sustainable. Greater clarity is required in order to understand if this policy would be successful in its aim. Cluster 5 fails to achieve the following LP1 criteria:

• Enhance and maintain the local character • Protect and enhance the natural environment • Located so as to reduce the need for travel • Minimal reliance on the private car

Vinson (ID343) Clusters 5 and 7 do not offer a sustainable environment, priority should be given to more sustainable sites in Bracknell.

Winkfield St Marys School (ID428, 430, 1188)

Seek assurance that there would be no environmental hazards from construction of the development including noise, use of hazardous materials, smoke or particles.

Griffiths (ID462) Bennett (ID758)

Traffic congestion on Locks Ride, Forest Road, Braziers lane during daily rush hours will be exacerbated if the development went ahead, and will impact negatively on local air quality.

Kesselman (ID476) Concern at potential noise pollution from proposed school. Bollen (ID506) Bruen (ID330) Increased traffic on local roads will cause increased pollution and

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Wilcock (ID737) Bartlett (ID1497)

have a harmful impact on health (Locks Ride/Forest Rd specifically mentioned) harming quality of life for residents. Particular issue at peak times.

Skudder (ID501, 664) New spur road subject to potential flooding where it joins Braziers Lane. Has photographs from March 2018 showing sitting water at the north east corner of the SANG all the way along the northern boundary. Ditches adjacent to the Braziers Lane / Forest Road junction were inundated and overflowing. Repeated remedial work has not solved flooding problems.

TRANSPORT

Taylor (ID51/143), Morrow Concerns regarding highway safety, local roads/junctions already (ID68), Willshire (ID78), Murphy congested, used as rat runs, will not cope with additional traffic, (ID85, 461), Calcuut (ID90), existing 20mph speed limit along Winkfield Row. Green (ID95), Foulkes (ID121), Specific roads/junctions referred to in comments include: Turner (ID123), Smith (ID134), • Forest Road junction with the A330; Willshire (ID136), Dorman • Winkfield Row (B3017) from Forest Road to Bracknell Road (ID137), Kesselman (ID140), (B3022) (used as a rat run in rush hour; Gamble (ID142), Hoad (ID151), • junction outside Don Beni is dangerous, Dyer (ID166), Vinson (ID182, • road past the front entrance to Winkfield St Mary Primary 187, 341), Brett (ID188, 189, School is dangerous; 196, 197, 198, , 216, 224, 516) • junction of Winkfield Row/Forest Road (outside Row Farm); Saunders (ID299) Horsfield(ID355) Andrews (ID446) Griffiths (ID462) Chavey Down Association (ID456) Jarvis (ID488) Bollen (ID506) Evans (ID508) Overd (ID513) Ward (ID517, 518) Wing (ID545) Gill (ID552) Stolagiewicz (ID556, 937) Luker (ID594) Van Oefferen (ID316) Ganachaud (ID617) Bennett (ID758) Lyes (ID792, 883) Day (ID759) Townsend (ID 864) Smith (ID 886) WRRA (ID941) Murphy (ID1011) Piper (ID 1049) Glennerster (ID 1151, 1166) Gunn (ID 1158) Beidas (ID 1224) Fazey-Gunn (ID 1238) Ward (ID1250) Browne V (ID 1304) Browne J (ID 1306) Gaw (ID 1390, 1391)

• junction of Braziers Lane/Forest Road; Chavey Down Road; Locks Ride).

• junction of Braziers Lane with Pigeonhouse Lane • junction of Forest Road and Hatchet Lane • junction of Chavey Down Road and Bracknell Road at Brock

Hill • Maidens Green crossroads just north of the "Stirrups" Public

House/Restaurant and north of the "Oaktree" Garden Centre • Martins Heron roundabout on the A329, (jams are already

saturating the 4 roads connected to the roundabout at rush hour and traffic lights here will exacerbate the jams)

Local roads are country lanes not designed to cope with high levels of traffic and little scope to improve them. Forest road is an alternative route between Bracknell and Ascot particularly when there are holdups on the A329. The proposed development and others close by will only add to the congestion. New school will attract more traffic to the area. Estimated 4550 new trips from 500 based on recent planning application in the area (17/00160/OUT). Proposed cycleway, footpath & highway improvements will not address congestion and safety Reference made to combined impact taking account of new housing at Woodhurst Park/Blue Mountain, Amen Corner, new mobile homes at Warfield Park, Mushroom Castle, Hayley Green and other sites including in Wokingham, traffic generated by Lambrook School; Local area is already congested with commuter traffic. Proposed measures will not mitigate the transport impacts, developments could cause gridlock. Most cars break existing speed limits.

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Jarvis (ID 488) Forest Rd is overloaded already and additional development will make it worse.

Skudder (ID501, 664) Concern about putting new link road through green space from Forest Rd to Braziers Lane

Francis (ID55) The bridge over The Cut is single track, how will this cope with additional traffic.

Lyes (ID792) Smith (ID886) WRRA (ID941) Gaw (ID 1390, 1391)

New link road parallel to Braziers Lane could attract more traffic including HGVs to use this route which not be appropriate close to a school / residences.

Lyes (ID883) Proposed road through the new housing will be used to avoid queues at the end of locks Ride and become very busy and drivers will not keep to the speed limit. The road will divide the new communities which isolated islands of development surrounded by roads.

Morrow (ID68), Calcutt (ID90), Hoad (ID151) Luker (ID594) Van Oeffelen (ID316)

Proposed new road arrangement / Chavey Down will act as a rat run between the M3 and M4, and existing roads (Braziers Lane) used as a rat run (advocated by the AA during Ascot week)

Murphy (ID85), Calcutt (ID90) Existing 20mph speed limit along Winkfied Row has not slowed traffic, and ramps create noise problems, will worsen (additional vehicles/further risk of accidents).

Murphy (ID85) Dangerous and difficult for residents to cross the road. Murphy (ID85) On bin days public cannot use footpaths and have to walk on the

road, including people pushing prams which is dangerous. Williams (ID356) Document LP/Ev/4f highlights poor accessibility and public transport

links to rail services, and long distance bus routes for access to employment, shopping facilities and healthcare. This would put greater strain on local road network from additional car journeys.

Green (ID95) Addition of two new primary schools (Hayley Green and Winkfield Row) will increase traffic on Forest Road, which will not be able to cope. Are the schools necessary for this level of development?

Griffiths (ID81) Vinson (ID348) Comments made about Transport Accessibility Statement. Does not agree with there being no congestion hot spots near Cluster 5. Have witnessed accidents on the Braziers Lane cross roads. Forest Road is extremely busy. Queues on Locks Ride are frequent. Very little public transport. (Comments also summarised under evidence base).

Willshire (ID136) What proposals are in place (including by RBWM) to improve junctions on Forest Road (taking account of Woodhurst Park development and LP7)?

Dorman (ID137) Trains are at full capacity in rush hour. Luker (ID594) Forest Road could not cope with increased traffic movements

without a complete change to the infrastructure and there is not the scope to implement this

Saunders (ID299) Station car parks cannot cater for any more cars and off street parking is becoming a problem. Lack of public transport.

Dorman (ID137) Wilcock (ID737) Ward (ID1250)

Not enough buses / bus services are inadequate and no proposals to increase services.

Menon (ID 1534) The estate will lead to a significant increase in local traffic Cawood Scientific Ltd (ID154) Operate an agricultural laboratory, and the SANG area is proposed

behind the laboratory. Concerned regarding suggested closure of

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Braziers Lane will have serious impact on 30% of staff. Concerns regarding impact on deliveries if roads are closed, many alternative routes unsuitable for HGV, or would go past existing play areas, or through the proposed SANG area. Road closure will have a serious impact on the business.


Braziers Lane needs to be upgraded.

Vinson (ID177), Brett (ID197, Primary school(s) will add to existing traffic, road network will not 198) Evans (ID508) Taylor cope. No mitigation measures proposed for this. (ID581) Dorman (ID 589) Lyes (ID791) Vinson (ID182, 348) The Council have not used up to date traffic data and do not Stolagiewicz (ID556, 937) recognise current traffic conditions. Dorman (ID 589) Murphy (ID644) Vinson (ID183, 341) Evans Sites have poor scores on transport and very limited accessibility, (ID508) Gill (ID552) Luker and does not meet Policy LP1 in terms of a location reducing the (ID594) Skudder (ID501, 664) need to travel and minimal reliance on private car. Site is not as well Murphy (ID627, 628, 644) located as other alternatives. Sites suffer due to the lack of access

to pedestrian / cycle network and do not score well on proximity to rail stations, long distance bus routes or access to employment / health / everyday services and facilities. Cluster 7 is ranked in the bottom group for accessibility, with a score of 0 (Draft Transport Accessibility Statement, section 6, Table 10). No other site in Warfield is ranked in this group, and no other site in this group is allocated in the draft BFLP.

Vinson (ID 348) New spine road in cluster 5 should not be used as a cut through by HGVs

Brett (ID188, 189, 196, 224) Documents written by someone without first hand knowledge, such as cluster 5 having no congestion.

Eustace (ID 1370) Strongly object to new link road and closing off Braziers Lane. Their brownfield site is accessed from Braziers lane and access to the public highway cannot be removed. Closure of road unnecessary and will leave a long stretch of road which will attract fly tipping /become unsightly. Existing road should be left in place and if necessary a diversion is made around the cottages at the cross roads to overcome any perceived access issues. All sizes of vehicles currently access Laboratory site without difficulty and no need for a new road which would be expensive to build and disruptive to the Green Belt.

Brett (ID197, 198) Saunders Existing cycle paths on roads, tiny footpaths not wide enough for two (ID299) Vinson (ID348) Ward adults to walk side by side. Footpaths on Locks Ride are too narrow (ID517, 518) Gill (ID552) Lyes for pushchairs to pass. Narrow footpaths in area and no room for (ID791, 792) Smith (ID886) widening including to form cycle paths on Locks Ride. Roads are WRRA (ID 941) Ward (ID1250) dangerous for cyclists. Reference to Locks Ride Appeal Inspector’s Gaw (ID 1390) comments on lack of footpath between Locks Ride & N Ascot. Not

clear what improvements are proposed / which part of Forest Rd would be improved.

Brett (ID197, 198, 202, 203) Equine safety not planned for (highway code horse warning signs, but no support is planned for them being on the road) (told at

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exhibition that no plans have been made for horses to be on the road).


Draft plan with outstanding housing commitments (February 2018) takes number of additional dwellings to nearly 1,500 in Winkfield Parish, (approx 23% increase on 2011 census and 37% increase for the Ascot Ward). These increases in combination with proposed 700 dwellings on the A329 in Ascot on border of BFC/RBWM, will place enormous pressure on infrastructure Do not believe BFC’s proposals for the route are realistic without a fundamental change to the structure of this road, which would not be possible given existing geographical constraints. Urge BFC in duty cooperate with RBWM to seek appropriate transport solutions.

Cross/Barnett 227 Supports closure of southern part of Braziers Lane. It would seem more logical to move Braziers Lane to the West and create a new crossroads rather than the ‘dog leg’ arrangement shown on the concept plan. This would help deal with the substandard existing junction and cater for additional traffic generated by new development to the north The new junction could be signalised Braziers Lane should be closed at the earliest opportunity when construction starts on the new development. The northern section of Locks Ride could be closed to divert traffic away from this substandard junction. If it remains open, the junction should be improved to reduce delays / improve safety. Forest Road should be traffic calmed in both directions from Somerton Farm to the intersection with the B3017 at Winkfield Row regardless of any road closures in the area.

Bruen (ID335) Winkfield Row/Hayley Green, already poorly served by public transport, Forest Road and Winkfield Row are used as a cut through. 1,000 more cars will cause problems. Traffic speed already exceeds limits particularly the 20 mph zone running past Lambrook School

Vinson (ID348) Fullerton Staggering the Braziers Lane/Forest Rd/Locks Ride junction will (ID353) Williams(ID356) result in complex manoeuvres, cause delays and pollution/noise. No Skudder (ID501, 664) Gill viable proposals have been put forward for how this will be handled. (ID552) Proposed changes are inadequate to meet increased demands. Taylor (ID581) Bartlett (ID1497) There are already local congestion hotspots. Will create road safety Gaw (ID 1390, 1391) issues including with school traffic and pedestrian movements. Fullerton (ID353) Murphy Questions assumptions about vehicle movements per home and (ID644) Browne V (ID 1304) impact on peak hour journey times. Questions how increase in Browne J (ID 1306) traffic to Maidenhead for Crossrail will be handled and what are

plans for improving links to Martins Heron and Ascot rail stations. Lack of parking at Martins Heron Station / too far away to walk to.

Winkfield St Marys School Seek assurance that there would be no impact on the safety of (ID428, 430, 1188) pupils, staff and parents and carers whilst travelling to and from the

school site both during construction stage and following completion of the development.

The plans raise concerns about the safety of children, parents and carers and staff travelling to and from our School. Has the volume of traffic, congestion, footpaths and pollution been considered?

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Seek assurance that there would be no impact on safety in relation to vehicle movements at school drop off and pick up and that there would be no added congestion at drop off and pick up times due to additional traffic in the vicinity.

Is there a travel plan for the new schools that provide assurance that there will be no disruption to WSM?

What plans are there to improve the road and pathway infrastructure within and around the planning development areas?

Andrews (ID446) Plans should include improvements to public transport which is presently inadequate and does not serve the major employment hubs.

Griffiths (ID462) Stolagiewicz Proposed development area is poorly served by public transport, (ID556, 937) Dorman (ID589) with no easy access to trains or buses. Residents in proposed Luker (ID596) Van Oeffelen units would need at least 1 or 2 cars each. Martins Heron has no (ID316) car parking capacity to support additional vehicles. Conflict with Prior (ID740) Fazey-Gunn (ID Policy LP1. 1238) Kesselman (ID476) Traffic on Chavey Down Rd / Forest Rd already heavy. Development

would make congestion intolerable and dangerous. Gill (ID552) Cycle paths and subsidised bus routes will not have a significant

impact on site sustainability. Gill (ID552) Insufficient information to know what traffic issues will be following

further development in the Winkfield area. Stolagiewicz (ID556, 937) New spine road linking Braziers La and Forest Road and access

road onto estate south of Forest Rd would exacerbate existing problems and no room to widen the road. Pedestrians crossing Forest Rd to access new school, would also increase and any regulated crossings would increase journey times along Forest Rd.

Taylor (ID661) Proposal for new link road from Braziers Lane to Forest Rd is acknowledged, but new road from Forest Rd to Locks Ride seems inefficient. Suggests roundabout at junction with Forest Rd and new roads to north and south to east of existing junction (shown on alternative layout plan) Suggests Forest Rd could have peak hour traffic calming from new roundabout to traffic lights at junction with Chavey Down Rd.

Taylor (ID581) Virgo (ID616) Concerns about quality and age of data used in transport modelling Skudder (ID501, 664) Day and asks whether any realism tests have been carried out to validate (ID759) WRRA (ID 942) Gaw modelled flows. Questions robustness of 2013 journey time data (ID 1390, 1391) and does not believe that they reflect current conditions. 2013

automatic traffic counts did not include count points close to Cluster 5. Newer more robust data should be used, six journeys on a number of key routes by BFC staff is not sufficient and results look unrealistic..

Skudder (ID501, 664) Concern at lack of evidence that proposed highway changes will be effective. Local evidence of extensive congestion. More accurate up to date surveys are required (Jaynic 2102 survey is out of date). Concern at lack of local knowledge of planners.

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Taylor (ID581) Luker (ID594) Concerns about traffic accessibility assessment in that it does not Van Oeffelen (ID316) Lyes identify a well known local congestion hotspot at the Locks (ID792) Glennerster (ID 1166) Ride/Braziers Lane crossroads with Forest Road. Lack of available Gaw (ID 1390, 1391) evidence on how the Council’s conclusions on this were reached.

Assessment conflicts with the IDP identified Cluster 5 junction capacity improvement requirements. More homes on other sites will add to congestion.

Dorman (ID 589) Browne V (ID Concern at lack of detail on highway and junction proposals when 1304) Browne J (ID 1306) there is limited scope to widen roads due to land constraints.

The plan does not properly address how the significant increase in traffic will be accommodated. Traffic surveys are required in Braziers Lane / Forest Rd area.

Luker (ID594) Virgo (ID616) Murphy (ID644)

No detail provided on footpath and cycleway improvements. Conflict with Policy LP45.


Cluster site 5 entrance is a short distance from Church Road. Its dominance of Forest road and the proposed new spine road within the new site closing part of Braziers Lane will increase traffic, pushing traffic further down the line onto Church Road A330 T junction, drawing the settlements closer creating further infill areas in the future, with traffic spill into The Winkfield Conservation area, with its fast bends in front of Winkfield St Marys Church Grade II* Listed and The White Hart Pub Grade II listed, The Old Rectory Grade II Listed. As referred in The Winkfield Chronicles researched by local historian Ruth Timbrell.

Virgo (ID616) Lack of information on traffic flows and highway solutions, particularly dealing with traffic using local roads to access the M4. No proposed improvements to existing highways.

Blackburn (ID 1101) Spine road is a very good idea so that the Braziers Lane/Forest Road/Locks Ride crossroads problem junction is dealt with

Provision of green routes along Forest Rd is commended but how far along Forest Rd will they go and will they lead to the new school?

Ganachaud (ID617) Concerned about increased traffic Fullerton (ID 729) No evidence of BFC financial commitment or ability to provide the

vast improvements required to the footpaths and roads in the to ensure increased risk to pedestrians / road users is minimised.

Prior (ID740) Lyes (ID792) Changes to Braziers Lane will make it more dangerous, especially WRRA (ID941) around primary schools and have a negative impact on

health. These small local roads are already filled with speeding motorists.

Murphy (ID644) Forest Rd junction improvements are sole strategic enhancements for Policies LP6 and LP7 and are unlikely to cope with traffic generated by 1000s more houses in the area.

Pressure on inadequate rural road network in Policy LP7/Policy LP6 area will increase. Travel choice options will still be limited as acknowledged by the Draft SA scores for Objective SA17.

Proposals put heavy pressure on the narrow, rural largely B-road network of northeast Bracknell There is already congestion at

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bottlenecks leading to A-roads. Planned enhancements seem somewhat limited given the scale of increased traffic that can be expected.

Lyes (ID791) No indication of what the IDP reference to ‘further improvements to the network within 3km of the site’ would mean (with reference to footpath & cycleways).

WRRA (ID941) New spur road to south of Forest Rd could have road safety issues due to the level of traffic it could attract through what will be a residential area.

INFRASTRUCTURE


NPPF says infrastructure delivery is an important part of Local and neighbourhood plans. Infrastructure delivery will require considerable funding for many requirements (some not yet identified e.g. senior school) there are no costings or information on this crucial issue

If all funding is from CIL/ 106 payments and due to isolated locations of most proposed sites they cannot use existing services and will bear extra cost for new services. Without an audit of this the land may not be correctly priced or the CIL revenue calculated which could affect both parish and borough councils revenues.

Cornwell (ID67) No further mass development in the Northern Arc of Bracknell especially in Winkfield Row, as the area cannot cope with the additional traffic, schools with additional children and the lack of open space.

Fazey-Gunn (ID 1238) BFC’s lack of money for infrastructure should be a reason not to build so many houses.

Blackburn (ID 1101, 1103) 500 residential units is not enough as this number is below a threshold where appropriate facilities and services will be provided for the benefit of all in the local community.

Even when combined with other nearby sites the numbers are not enough to support significant new facilities which is bad news for local residents.

Provision of primary school, SANG and spine road is not enough for the local community. Transport infrastructure, local amenities and affordable housing are not mentioned in any detail if at all in the planning document and most likely will not be provided by the current development proposals.

The original WINK14 site should be reinstated and would have following advantages:

1. Level of development that demands more improvement in facilities and services for local residents than what is currently proposed

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2. Development of non-greenfield land as the land north of Forest Road in the old WINK14 is not greenfield

3. More flexibility with land provided SANG – land north of footpath on NW corner of previous WINK14 is very attractive with existing lakes, mature trees and hedgerows

4. Possible connection between the new and existing Primary Schools

5. More car parking and recreational options, especially for St Mary’s School if it is to be retained once new school is built

6. Existing agricultural buildings at Box Farm could be redeveloped – new school may be located in wrong place and may be better opposite existing school and additional SANG located here.

Current proposals are not properly co-ordinated and are a halfway house that fails to bring significant infrastructure improvements / new facilities do not maximise public open space available for residents.

Willshire (ID78) Vinson (ID345) Proposals include a new primary school, will the existing school Horsfield (ID355) Jarvis (ID488) (Winkfield St Mary) close? Concerned that new school will lead to Murphy (ID627) Lyes (ID791, the closure of the existing one. Question rationale for 2 more 792) Day (ID759) Smith primary schools in the area and they would increase traffic. Concern (ID886) WRRA (ID 938, 941) about putting another school on an already busy road. School Blackburn (ID 1101) Maidens seems poorly located on the extreme edge of the development. Green Society (ID 1154) Queries whether development will generate enough pupils to require Beidas (ID 1224) Ward the new schools proposed in the Plan and what other areas would (ID1250, 1252) Browne V (ID be served by them and potential traffic implications if pupils travel 1304) Browne J (ID 1306) Gaw from further afield. Lack of evidence of consultation with education (ID 1390) Menon (ID 1534) providers. Blackburn (ID 1101) Parking for SANG and school appears insufficient. Virgo (ID616) Lack of meaningful engagement on schools and lack of information

on current schools / numbers. Murphy (ID85), Dorman Area already suffers from sewage problems, and cannot cope with (ID137), Gamble (ID142) further development. Significant investment required to improve Dorman (ID589) Luker (ID594) sewerage and drainage and there are no details of this in the Draft Murphy (ID627) Local Plan. Bruen (ID93), Williams (ID125), Doctor Surgeries (and dentists) in the area already over capacity Brown (ID131), Dorman (ID137, (Primary school is the only new community asset proposed). Site 589) Vinson (ID345) Williams specific infrastructure requirements should include health. (ID356) Griffiths (ID462) Reference patient survey at Gainsborough surgery showing patients Andrews (ID446) Jarvis (ID488) main concern is access to appointments. Population should not be Ward (ID517, 518) increased without sufficient health care plans. Stolagiewicz (ID556, 937) Lack of meaningful engagement on health. Luker (ID594) Van Oeffelen (ID613)Virgo (ID616) Wilcock (ID737) Prior (ID740) Bennett (ID758) Lyes (ID791, 792) Wallen (ID825) Bartlett (ID1497) WRRA (ID 941) Piper (ID 1049) Gunn (ID 1158) Fazey-Gunn (ID 1238) Browne V (ID 1304) Browne J (ID 1306)

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Williams (ID 1353) Gaw (ID 1390) Lyes (ID791, 792) WRRA (ID 938, 941) Gaw (ID 1390)

The SA says Health Care provision is within the IDP, however the IDP states for all proposed sites: “No site-specific infrastructure requirements identified at this stage but to be considered further for the Draft Submission stage of the BFLP. Acute Care and General Hospital infrastructure could be provided within multifunctional community centre/hub capable of serving the site.” IDP also states that more information is required regarding existing capacity of surgeries and funding sources. This is insufficient detail for consultation and its importance the public should be able to consider the options as part of the overall Draft Local Plan. Brants Bridge / Skimped Hill proposals in IDP not a solution for Winkfield Row residents as transport is poor. No evidence of meaningful consultation with NHS or CCG. No specific sites identified to meet health needs.

Turner (ID123), Smith (ID134), Dorman (ID137), Greenan (ID138), Brett (ID190, 191, 216, 516) Glover (ID511) Scutt (ID510) Gill (ID552) Prior (ID740) Murphy (ID 1011) Gunn (ID 1158) Browne V (ID 1304) Browne J (ID 1306)

Infrastructure will not cope/unsuitable for new development (comments include reference to not enough shops, public transport).

Proposed developments including at Warfield will put intolerable strain on infrastructure that is already under pressure.

Smith (ID134) Virgo (ID616) Lack of existing footpaths and street lighting. Dorman (ID137) No detailed information on how infrastructure will work. No detail on

school size, footpath cycle ways, healthcare, community centre, flood prevention.

Hoad (ID151) Gunn (ID 1158) Beidas (ID 1224) Fazey-Gunn (ID 1238) Gaw (ID 1390)

Insufficient secondary school places (parents have to go private or to RBWM), a new school should be built as a priority. IDP identifies need for secondary school but no site is identified.

Taylor (ID661) Wilcock (ID737) Footpaths shown on Map 6 are a useful amenity – should be more integrated footpaths and cycle paths, in and around Winkfield Row. This could cultivate greater use of the local rural areas which are now only accessible using busy roads, like Forest Road, Chavey Down Road or Locks Ride.


Shops units need to be included to reduce private car usage.

Lyes (ID791, 792) WRRA (ID 941) Beidas (ID 1224) Browne V (ID 1304) Browne J (ID 1306)

Lack of Community centre / multi-functional hub to serve Winkfield (and Bracknell Town Centre) Important as hubs are seen as providing for a variety of needs (including GP / retail). Carnation Hall already heavily used.

Lyes (ID883) Cluster 5 proposals conflict with Policy LP 9 due to lack of clear information on mitigation/provision for water supply, education, health and broadband and wrongly assumes that BFC will negotiating with a single developer.

Lyes (ID796) Cluster 5 only makes provision for a school, this level of infrastructure delivery is unsatisfactory.

Ward (ID1250) How has the assessment been made in respect of roads, public

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transport, schools and healthcare? Lyes (ID883) Policy LP 9 says development proposals must demonstrate that they

mitigate impact on local infra-structure including broadband. The scale of development proposed for Cluster 5 will increase the load on the broadband infrastructure and the plan has not demonstrated how the impact will be mitigated to protect the current service (which is below the government target) let alone provide superfast services.

Vinson (ID177, 183, 345) Luker (ID594) Stolagiewicz (ID556, 937) Gaw (ID 1390)

No plans for any built communities facilities/hub (including health facilities)

WRRA (ID955) Policy LP 9 wording means that only one element of infrastructure might be provided rather than all necessary measures – for Cluster5 this could be just the school which is unsatisfactory.

Saunders (ID299) Bollen H (ID506) Bollen R (ID507) Ganachaud (ID617) Fullerton (ID 729) Townsend (ID 864)

Schools, doctors and hospitals are overloaded

No evidence of how necessary education, healthcare, public transport would be provided.

Bruen (ID331) Gill (ID552) Dorman (ID589) Bartlett (ID1497) Townsend (ID 864) Smith (ID886) Beidas (ID 1224) Menon (ID 1534)

Lack of community facilities such as access to medical centres, shops - one local supermarket otherwise having to drive further afield again causing additional pollution. Lack of existing local shops. No sports facilities proposed.

Griffiths (ID462) The local School, Winkfield St Mary’s is at full capacity, all classes have 30-31 children – so there is no scope to absorb additional large numbers of children

Scutt (ID510) If infrastructure is provided to accommodate the development Winkfield Row and the area around Bracknell will no longer have any merit as a place to live.

WRRA (ID 941) Cost of infrastructure to deal with flooding problems in the area could affect site viability and no information is provided on costs/viability in the plan.

SUSTAINABILITY ASSESSMENT

Gill (ID552) WRRA (ID 941) Greenan (ID 1187)

Plan contains assertions of sustainability based on arbitrary scores with no evident rationale. More explanation and joined up thinking is needed about why the proposals are sustainable.

Brett (ID188, 189, 196, 216, 516) Virgo (ID616) Lyes (ID791, 792) WRRA (ID 941) Greenan (ID 1187) Gaw (ID 1390)

63% of the sustainability objectives in Cluster 5 have a negative rating which is the highest for any proposed allocation site. 25% of the SA objectives are ranked as very negative (SA4a , SA4b , SA6 and SA7) Site is not suitable for allocation. There should be pre-determined benchmarks for scoring criteria so that the scoring can be better understood. Criteria need to be more explicit.


Sustainability Assessment Winkfield Row Policy LP6 • Cluster 5 does not appear to meet LP1 • Relatively isolated site travel by car required

Wing (ID543) Concern about quality of data used and criteria used for Sustainability Assessment.

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Virgo (ID616) Lyes (ID791, 792, 883) Greenan (ID 1187)

Health Objectives SA12 is ranked as positive which is simply not the case. GP surgeries are over-subscribed and no clearly identified additional provision, there are road safety and congestion concerns, highway proposals will have a negative impact on traffic problem and on health.

Lyes (ID883) No assessment against SA1 which skews the decision process. Virgo (ID616) Lyes (ID791, 792) WRRA (ID 941) Greenan (ID 1187)

SA17 Travel choice - residents are forced to use motor vehicles due to poor bus service and no cycle lanes. Dangerous to cycle on narrow roads not designed for the huge amount of traffic (including heavy trucks) that are a regular part of the day. Cycle paths and subsidised buses will not have a significant impact and bus services are being reduced.

Lyes (ID791, 792) WRRA (ID 941) Greenan (ID 1187)

SA9 is ranked as positive but only employment is a school of undefined size. Wink 22 and Cluster 7 both have schools allocated but achieve a “neutral” score which appears inconsistent.

Lyes (ID791) WRRA (ID 941) SA section 3.196 says further work required to further determine nature and significance of effects and the measures required to prevent, reduce and as fully as possible offset any significant adverse effects. This will include viability and education. Without completing this work the Draft LP cannot be effectively assessed.

Lyes (ID883) SA7 – is about use of water. With reference to cluster 5 the Water Cycle Study says infrastructure improvements are required to accommodate growth in the area but this is not reflected in the IDP or in the summary for the cluster on P50 of the Draft LP. This could skew the decision making process.

Lyes (ID883) SA16 Services is amber but only proposed new facility is a primary school. Landowners may be reluctant to provide land for new school. No plan for any new medical facility no specific requirements in the IDP or summary of the site in the Draft LP. This could skew the decision making process with regard to the sustainability of this site.

Vinson (ID 342) SA section 3.196 says further work is required to determine nature / significance of effects and measures needed to mitigate them. Plan cannot be effectively assessed until this work is done and the results made public. Clusters 5 & 7 do not meet some sustainability criteria and many SA objectives are rated negatively for them.

OTHER MATTERS

Bruen (ID93) Other application (17/01051/FUL) has been rejected for reasons which are relevant to this development (poorly located to services and facilities, with inadequate non-car borne modes of transport, and harmful urbanising impact on the character and appearance of the site).

Prior (ID740) Areas selected for development were previously said to be unsustainable. What has changed to make them now eligible?

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Menon (ID 1534) It would be better to integrate the public open space and housing together rather than having a Forest road separate the two.

Bollen H (ID135, ID506) Bollen R (ID507) Virgo (ID616) Foulkes (ID121)

Proposals unsustainable, reference the many arguments BFC made against the recent ‘Gladmans’ proposal for 88 homes west of Locks Ride.

Van Oeffelen(ID613) Evidence base is out of date Kesselman (ID140) Existing properties will devalue. Richardson (ID 1496) Cluster 5 raises potential land assembly and infrastructure issues

that could delay bringing forward the overall site and its package of measures in each case.

Hoad (ID151) Other proposals in the area have been declined (Winkfield Row/Forest Road), reasons relevant to this site.

Dyer (ID166) Winkfield Parish have proposed smaller separate sites which would have far less impact than the proposed site.

Dyer (ID166) Other sites better suited to development due to better location of services, amenities and transport, as this part of the Parish is relatively isolated, and potential to expand existing infrastructure is limited.

Lyes (ID791, 883) Need for reduced water consumption in new homes and necessary upgrades to water supply will affect viability.

Wallen (ID825) Development should be considered in conjunction with Hayley Green proposal LP7.

Vinson (ID177, 180) The site does not offer a sustainable environment, sustainable transport or sustainable facilities, and does not fulfil the vision set out in para. 3.1, nor follow National Policy guidelines as set out in para. 5.23.

Vinson (ID178, 181, 185, 342, 345)

Site is contrary to the sustainable development principles of Policy LP1.

Vinson (ID183, 184, 345, 346) Funnell (ID361) Evans (ID508) Wing (ID 546) Wilcock (ID737) Prior (ID740)

The development does not provide employment, which means everyone has to commute out. Why does SA9 rate cluster 5 positive when there is no employment in the area. Concern at lack of employment creation within the proposal.

Vinson (ID183, 345), Brett (ID188, 189, 196) Beidas (ID 1224)

The sites proposed in Winkfield were previously viewed as unsustainable (10 years ago) – nothing has changed/things have only got worse, so why are they now deemed suitable?/what has changed since 2010?

Brett (ID188, 189, 196, 216, 516)

Content for Cluster 5 is contradictory. A lot of the content is vague and needs to be ‘considered further’.

Brett (ID188, 189, 196, 216, 516)

Impossible to comment on draft plans that are inclusive as stated by officials attending the consultations, as not true plans.

Fullerton (ID 729) Insufficient detail on the proposed development in the consultation. Brett (ID194, 195, 216, 516) Cluster 5 was rejected in 2010, what has changed? Saunders (ID299) The whole area is surrounded by Crown property why are these not

being considered. Bruen (ID330) Separating Winkfield and Warfield sites is disingenuous, both

proposed developments would affect both communities. Horsfield (ID355) Griffiths (ID462) Piper (ID 1049)

Brownfield sites should be fully utilised before countryside including many empty offices in and around Bracknell (and reference to site of “The Foresters”). BFC should encourage building upwards, preferably on brownfield sites. Good quality retirement

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accommodation could provide higher density development reducing the need to build in the countryside. Development should be more evenly spread across the borough – Winkfield is being hit very hard.

Gorlowski (ID470) Wing (ID Brownfield sites within existing urban areas would be much more 543, 547) Kasaska (ID996) suitable for residents and they could be supported much better by

the existing infrastructure (Roads, Public Transport, Schools, Medical centres, Utilities etc) Brownfield first policy should be included in the Plan. Brownfield register is only proposed to be updated annually which is the minimum requirement. Ministry of Housing April 2017 states that communities will be able to highlight local derelict/under-used sites for redevelopment. This can bring investment to the area and increase the number of new homes in the area.

Williams (ID356) Kesselman Inadequate consultation, information was confusing, consultation (ID476) Bennett (ID492) period not long enough, website difficult to navigate, Too much Skudder (ID 501, 664) Bollen H technical language. Not all documents available at the start of the (ID506) Brett (ID516) Ward consultation. Winkfield consultation event was too crowded / in a (ID517, 518) Wing (ID543) Gill small room / not well publicised / not at convenient times. Staff gave (ID552) Stolagiewicz (ID556, glib answers. 936) Too much information for people to respond to. Dorman (ID589) Luker (ID594) There has not been early and meaningful engagement with Van Oeffelen (ID613) Virgo neighbourhoods as required by NPPF / SCI (ID616) Wilcock (ID737) Prior Item in Town and Country was not prominent enough. (ID740) Lyes (ID791) Day Exhibitions were information delivery rather than consultation as no (ID759) Smith (ID886) WRRA attempt to capture comments. Documents were too long to be (ID938) Kasaska (ID996) responded to in the time available.

Additional meeting venues / dates were offered but not taken up. Request for extension of the consultation period was rejected.

Ward (ID517, 518) Lyes (ID791)

Consultation portal was hard to use and changing password did not work. May put people off commenting.

Winkfield St Marys School (ID429, 430)

Want to know that WSM would not be disadvantaged by proposed new schools in the area. Wish to meet to discuss options for WSM and understand impact on WSM as a faith school. Wish to know how school capacity has been calculated and what plans the LA has to work with WSM as the plan progresses.

Andrews (ID446) No rationale in the proposal document as to where the additional population will be employed. Unrealistic to expect them to be employed in the Bracknell - more common for local residents to be employed in west London, central London, Slough, Maidenhead, or Reading. The proposed plan does not reflect this reality.

Scutt (ID764) Objects to Winkfield Row proposal – if all other proposals in the area go ahead it will overload infrastructure. Appears developer is reluctant to finish new apartments at Woodfield Park – does this mean new houses are not needed?

Griffiths (ID462) Wing (ID544) A longer term, more sustainable and sympathetic proposal is needed, that is easier for residents to review and debate, that address the real challenge of the regional development needs, but protects this special landscape for future generations.

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The Plan does not provide a longer term vision and appears as a 15 year plan to deliver housing numbers.

Kesselman (ID476) Concerned at loss of privacy/daylight/view if adjoining field developed. Impact on value of property.

Smith (ID 886) Concerns about Berkeley development at Woodhurst Park – lack of off-street parking and lack of space at SANG car park – concern about ongoing maintenance.

Kesselman (ID476) No detailed plan of exactly what the development will look like. Bollen R (ID507) The local community is working hard to develop a suitable local plan

recognising appropriate development. Scutt (ID510) The plan is social engineering on a vast scale.

Wing (ID546) Virgo (ID616) Proposals represent over-development and the lack of infrastructure / community facilities / employment makes it unsustainable.

Taylor (ID661) Small scale flexible commercial space should be included in view of forecast increase in population – they could be owned by the Parish Council to provide local control over occupancy.

Beidas (ID 1224) No details of additional employment on the site. Skudder (ID 501, 664) Scutt (ID510) Glover (ID511)

Agree with comments of Warfield Parish Council

Glover (ID511) Central and local government must take a more imaginative and responsible look at development in the South East and London with a view to moving investment, jobs and housing to areas that so desperately need them. To continue on the present course will result in the South East facing gridlock, catastrophic breakdown in services and infrastructure and ultimately deterioration of social cohesion.

Bennett (ID529) Agree with the detailed response made by The Winkfield Row Residents Assoc

Lyes (ID791) Only 4 members of the public responded to the SHELAA – shows lack of meaningful attempt at consultation.

Lyes (ID791) WRRA (ID 938) Residents Associations should have been consulted with and the considerations listed in the SCI should have been addressed.

Gill (ID552) Impact of current large scale developments across Bracknell Forest and Wokingham are not properly understood.


As a C of E school, it is important that the strong Christian Ethos is maintained and considered in the development plans. This ethos is part of what makes WSM important to the local community. Proposals indicate multiple schools being built in the surrounding area, and its not clear what these schools will be in terms of size and status. Governors and the Diocese want to understand impact on WSM.


How are school capacities calculated to meet forecast demand and what plans are there for the LA to work with WSM as plans progress.

Dorman (ID589) Proposal conflicts with NPPF Core Principle 7 in that it has not allocated land of lesser environmental value – should look at brownfield sites and Crown Land

Richardson (ID1496, 854) Cluster 7 has land assembly and infrastructure issues that could delay delivery of the site and the infrastructure package.

Luker (ID594) Virgo (ID616) No viability assessment of the Local Plan so no certainty that

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Fullerton (ID 729) Lyes (ID791, 792, 793) WRRA (ID 941) Greenan (ID 1187) Gaw (ID 1390)

infrastructure/affordable housing listed for the site would be affordable or deliverable.

Vinson (ID 342) Government guidance says more detail may be needed where viability may be an issue – this is relevant to Cluster 5 but detail is lacking.

Taylor (ID661) The proposal to build 500 new houses at Winkfield Row, whilst concerning, if sensitively planned is an opportunity to improve aspects of the area for residents.

Taylor (ID661) Development of the plan should nurture existing village’s semi-rural nature and distinctive shape, while defining a central area that can become a local hub. Increased population should help drive new amenities for existing and new residents.

Taylor (ID661) Positions of new housing, SANG and school are wrong way around. A) Locating housing adjacent to Chavey Down Road and Locks Ride, would increase perceived density of built environment for most residents and harm semi-rural, open character. B) Locating SANG and school to the NE of the village, would cause long journeys on foot for school children and people accessing the SANG. It increases likelihood risk of these longer journeys encouraging more local vehicle use, rather than walking.

Taylor (ID661) Suggests locating housing to N of Forest Rd where landscape is not particularly visible, would reduce impact on local roads of traffic heading north, would better retain existing character of Forest Rd / Locks Ride

Taylor (ID661) Suggests locating new school at centre of village. Would reduce walking distances. Potential to combine with existing school to create high quality new building and re-use old school for community facility (e.g. GP surgery, dentist, pharmacy, chapel, art gallery/workshop). Also potential for new community hall.

Taylor (ID661) Suggests locating SANG to south of Forest Rd to make it highly accessible and well used area which could be ‘Winkfield Row Common’ with existing recreation ground relocated to within the SANG with a flexible pavilion building providing a range of functions such as café/shop

Taylor (ID661) Sketch Plan provided to illustrate alternative layout with housing development to north of Forest Rd..

Prior (ID740) Infill in the Winkfield Row area already means that multiple houses (and extra cars) are appearing. Feels that more houses will follow after the initial builds.

Murphy (ID625) It is premature to indicate developable area boundaries without complete information (e.g. flood, biodiversity, GI) and without appropriate design policy (e.g. large sites in linear settlements).

Lyes (ID792) WRRA (ID941) If new spur road south of Forest Rd requires significant land take then the proposed 500 homes may not be achievable – or would density increase?


Have concerns over the proposed development sites at Winkfield Row.

Society for the Protection of Recent appeal by Gladman for 88 houses at Locks Ride showed

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Ascot (ID806) unsustainable nature of this development. To suggest the area can accommodate a further 412 dwellings begs the question as to how the site can be made sustainable. Draft plan suggests required infrastructure will be self-financing from developer contributions. We await the proposed IDP with interest.

WRRA (ID 938) No link officer made available for the Neighbourhood Development Plan Group.

Collings (ID 1070) Do not know land well enough to comment. Blackburn (ID 1101) Favours development in the Winkfield Row area as current

infrastructure cannot cope with traffic volume and lack of local amenities and affordable housing and the bus service is currently poor. Important that demographics are right to support new town centre and with the right level of housing development these problems could be remedied.

Lyes (ID 1255) - petition with 1946 signatories

Submission of petition signed by 1946 signatories objecting to the proposed allocation. Petition was prepared in response to the SHELAA and re-submitted to Councillors in January prior to the Executive and Council decisions to proceed with the consultation on the Draft Local Plan.

The petition opposes development of up to 938 homes remains relevant. Less than twenty months ago, an application (14/01333/OUT) for 88 dwellings on land within Cluster 5 was opposed by BFC. The Planning Inspector judged the site was not sustainably located and out of character with the local area. Relevant matters relating to Cluster 5 are:

1. Contrary to proposed policy LP11 and NPPF paragraph 17 (Protection of Countryside)

2. Contrary to proposed policy LP12 (Landscape Character)

3. Contrary to proposed policy LP1: (Sustainable Development Principles)

a. enhance and maintain local character b. are located so as to reduce the need to travel c. minimal reliance on the private car.

4. Contrary to proposed policy LP18 (Design): a. Identifies and respects local heritage and patterns of development b. All development proposals must demonstrate that they are in general conformity with the design principles set out in other relevant Supplementary Planning Documents including the Character Areas SPDs,

5. The BFC Character Area Assessment for Area D :Winkfield Row South states that major new estate development could further erode the traditional linear settlement pattern.

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Collins (ID427) Has an interest in the industrial site on Braziers Lane (Title BK304607) . Were surprised to see the land excluded from the allocation and argue that all the land between Braziers Lane and the proposed allocation should be part of the allocation and within the new settlement boundary. While not available in the short term due to tenancy it is a brownfield site with clear development potential.

Strongly object to new link road and closure of Braziers Lane. The site is accessed from Braziers lane its access to the public highway cannot be removed. The closure of the road is unnecessary and will leave a long stretch of road which will attract fly tipping and become unsightly. Want the existing road left in place and if necessary make a diversion around the cottages at the cross roads to overcome any perceived access issues

Essential that Bracknell Forest Council (or similar body) take over formal possession and management of the SANG. in private ownership its delivery will be at risk and would be concerned about its ongoing management.

R2 Development Ltd [Agents Support principle of development at Winkfield Row as a sustainable Barton Willmore] (ID 865) location for growth. Village has number of facilities, including

primary school, and is within 2-5km of the facilities within Bracknell Town Centre and wider conurbation of Bracknell (equates to a 15 minute cycle ride mainly on cycle routes. Village is served by an hourly bus service.

Allocations in Winkfield Row would support existing facilities in the village as well as providing additional facilities and services which would enhance its future sustainability.

Winkfield is a sustainable location which is unconstrained by national designations and sites beyond the SPA buffer zones Therefore we consider it is suitable to accommodate housing to meet a proportion of the Council’s housing need in the next Plan Period.

The Council’s Draft Transport Accessibility Assessment at para 4.4.2 recognises status of Winkfield Row as one of the more sustainable locations in the Borough. Due to its level of facilities / services (village/community hall, primary school, public houses, bus route and a recreation ground) village has been considered by BFC to be a ‘settlement’.

Village is in close proximity to services on outskirts of Bracknell that are within cycling distance. Winkfield Row is within 5km of Bracknell Town Centre, which is generally accepted as a reasonable distance to cycle to access facilities and amenities.

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Most routes into Bracknell are flat 30mph roads suitable for cycling.

BFC has identified specific cycling routes linking edges of Bracknell to its Town Centre a number of which are (4-6min cycle ride) of Winkfield Row. Bracknell-Ascot route along A329 includes cycle paths, Harvest Ride is identified cycle-friendly, and there are off-road routes via Westmorland Park. This shows a sustainable and connected cycle route/network providing access from Winkfield Row to the town centre and station. It is a 15 minute cycle ride to Bracknell Town Centre 15 minutes using this network.

Bus services 162 and 162A connect Winkfield to Bracknell and Ascot, with stops at the Tesco North in Bracknell and the bus and railway station in Bracknell. Bus from Winkfield to Bracknell takes 25 mins, and runs every hour at Peak times and every hour to hour and 40 minutes at other times, including Saturdays. Earliest bus departs at 06.57 and arrives at Bracknell rail station at 07.22 which suits commuters. Buses continue late in the evening, with last service arriving at 23.02, which is appropriate for commuters and for spending the evening in Town.

It is therefore a sustainable location for growth which could support facilities and benefit existing and future residents.

R2 Development Ltd [Agents Winkfield Row is a sustainable location unconstrained by national Barton Willmore] (ID 865) designations or SPA. The village’s existing facilities and services,

together with its close proximity to Bracknell Town, make it an appropriate location to focus some growth within the next Plan Period.

We support the level of growth identified for Winkfield. The allocation of housing at Winkfield Row would help support existing facilities in the village and provide additional facilities to benefit existing and future residents.

It is important that the Local Plan follows the conclusions of the evidence base. The rationale for allocations at Winkfield Row, as a sustainable location, should set out more clearly how any ‘negatives’ could be turned into ‘positives’ through careful implementation and design.

R2 Development Ltd [Agents Support the Council in identifying Winkfield Row as having Barton Willmore] (ID 1131) settlement status (para 5.11).

Support the Council’s strategy to allocate development in sustainable locations unconstrained by the SPA, particularly in Winkfield.

R2 Development Ltd [Agents From our review of the Sustainability Appraisal that accompanies the Barton Willmore] (ID 1137) Draft Local Plan, it would appear that the Appraisal is overly

negative with regard to the scoring of a number of Sustainability Objectives for the allocations at Winkfield Row. In this regard, we set

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out below a review of two key objectives.

Objective SA17: Travel

Appendix 3 of the Sustainability Appraisal sets out the criteria and scoring method for sites and allocations per Objective. With regard to SA17: Travel, the objective scoring matrix has utilised the findings of the Draft Transport Accessibility Assessment 2018 (TAA), published by the Council. We have undertaken a review of the indicators within the TAA that were used to assess this Objective, and raise some concern with regard to the methodology behind the Indicators and their scoring.

The indicators used to assess the Travel objective include congestion hotspots, road improvements, cycling and pedestrian provision, access by foot to local centres, physical barriers, public transport access to the town centre, potential for public transport improvements and proximity to rail stations and long distance bus routes.

Agree with positive results for sites at Winkfield Row with regard to proximity to congestion hotspots, presence of physical barriers and potential for public transport improvements.

Concerned about scoring for cycling and pedestrian provision which is: 2 points – sites within cycle and pedestrian network 1 point – sites on the edge of cycle and pedestrian network -2 points – sites away from the cycle and pedestrian network.

No definition or plan in the TAA to define the ‘cycle and pedestrian network’ which each site is scored against, so unclear how far it extends to how close a site is to the network.

No differentiation between sites located ‘away from the network’ taking account of distance or suitability of routes that connect to the network. A site located ‘away from the network’ could be close/well linked to the network, but still score -2. This is misleading and the methodology and conclusions with regard to Winkfield should be re-considered.

The Proximity to Rail Stations criterion scores positively for sites within 800m of a rail station, but heavily negatively for all other sites, irrespective of their potential for accessibility to those stations. Winkfield Row is within a 15-minute cycle or 25-minute bus journey of Bracknell Rail Station, and the buses run hourly at peak times. While it is not directly adjacent to a train station, there are public or sustainable transport modes to access the station quickly. There

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should be greater differentiation between sites capable of sustainably accessing rail stations and those which are not. This would provide a more realistic understanding of the sustainable nature of each settlement.

The same point is made for access to a long distance bus route. Winkfield is within 1 mile, or a 20 minute walk, of route 702 which reaches London. It is not uncommon for commuters to walk for 20 minutes to reach their mode of transport.

Under a more detailed assessment, the Winkfield sites would perform better in terms of the Travel Objective and should be re-graded to at least ‘Neutral’.

SA sets out that sites at Winkfield Row have a ‘negative effect’ on this Sustainability Objective SA16: Services.

We have undertaken a review of the above indicators and the following concerns which we consider skews the conclusions and sustainability grading for Winkfield Row for this objective.

Consider TAA is overly restrictive on scoring criteria for accessibility to education. Education appears to be scored against the local centre criteria and is, as such, scored solely against accessibility by cycle and walking. Secondary education is often accessed by bus or coach. Restricting the scoring for Access to Education solely to cycling and walking does not provide a realistic understanding of the sustainability of the location in this regard.

The methodology for ‘Access to employment’ does not state how this is calculated. It is reasonable to assume that scoring would be based on proximity to public transport into employment centres, as it is common for employees to live in a different area to their place of work. This is relevant for Bracknell, given the transport connections onto London and Reading. Access to employment criterion sits together with education and health, and therefore, it appears that it has been assessed against the scoring matrix for walk and cycle access, which we consider to be misguiding. Further clarity is sought on the scoring for this Indicator.

Scoring criterion for ‘Services’ takes no account of other important facilities, such as public houses, community facilities, recreation grounds and shops.

Winkfield Row is served by a number of services, crucially including a primary school, regular bus service, community facilities and public houses. The village is within a 5km cycling distance of Bracknell Town Centre, which is the principal settlement in the District, as well as a 2km walking/cycling distance of the facilities on the edge of Bracknell, which include shops and GP. In addition, regular bus

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services provide connections to these additional services.

Consider the indicators used in Draft TAA not sufficiently comprehensive to properly assess sustainability of a location in terms of its accessibility to Services. Given the number of services Winkfield Row and its surrounding area do not agree that development here would have a negative impact on the Services Sustainability Objective.

Sustainability Objectives relating to SA4a Landscape, SA4b Historic and SA6a Pollution for Winkfield Row area were scored variably as positive/negative, negative or significant negative effect against these objectives. SA text says that for the sites and areas that have been proposed to be allocated, “the developable area was reduced to avoid the areas of highest sensitivity [in relation to landscape] and allow the recommendations of the evidence base to be incorporated into future development schemes” (paragraph 3.133). The potential for heritage impacts to be overcome has also been identified within paragraph 3.143 of the SA. As such, in our view, these objectives should be scored as ‘Depends on Implementation’.

SA6a Pollution objective recognises that for some sites in Winkfield Row, such as Cluster 5, there are only small areas of historic landfill, which could be avoided through sensitive implementation. It is therefore inappropriate for the overall scores to be ‘significant negative’, when allocations have been put forward with a sensitive layout to address this issue. This should be re-graded to ‘Depends on Implementation’.

Gladman (ID 1032) Support Policy LP6. Proposed allocation has the potential to make a sizeable contribution towards meeting the development needs of the area during the plan period. Gladman has an interest in part of this site, which forms a key element of the wider allocation (extent of land interest shown in enclosed plan).

Gladman confirm commitment to working with Council and other interested parties to enable timely delivery of site with view to accelerating anticipated start date in the Council’s trajectory. Emerging allocation is in a location that is suitable for housing development, there is a reasonable prospect that it will be available and can be viably developed at time envisaged by Council, or earlier in line with para 47 of NPPF.

Rumsey (ID 1451) The allocation of land for development at Winkfield Row under Policy LP6 is supported. It will provide an appropriate location to support the Borough’s housing and infrastructure requirements, in accordance with the NPPF.

More detailed comments are submitted in support of the allocation in a separate Paper entitled ‘ Policy LP6 – Land at Winkfield Row’.


Paragraphs 6.39 to 6.43 The allocation of land for development at Winkfield Row under Policy

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LP6 is supported. It will provide an appropriate location to support the Borough’s housing and infrastructure requirements, in accordance with the NPPF.

Eustace (ID 1370) Has interest in the industrial site located along Braziers Lane. Very surprised this land has been excluded from the draft allocation

All the land between Braziers Lane and the proposed allocation, should be included in the allocation and in the new settlement boundary. Braziers Lane is a clear defensible boundary and it is illogical to not include this land within the allocation now, especially as the site is brownfield land. Although the site is not available for development in the short term due to an existing tenancy, it is a large brownfield site with clear development potential and would easily become available for development within the timeframe set in the draft Policy. Issue has been discussed with the landowners of the land to the south and they have confirmed they will also make their land available for development as part of an allocation.

Woolf Bond on behalf of Warfield Park (ID1289)

The site should be omitted due to:

• Peripheral location in relation to key services and facilities. • Potential to have significantly adverse landscape impacts. • Previous planning history (dismissed appeal:

APP/R0335/W/15/3137269).


Constraints on the site include:

• Proximity of the Winkfield Row Conservation Area • Proximity of a Registered Park and Garden • Number of listed buildings • Flood zone 3 in northern part of the site – which will likely

restrict the developable part of the site to land south of Forest Road

• The site is in multiple ownership

Therefore, this is a risk that delivery of the site may be delayed and not be built out before the end of the plan period.

Concern also raised regarding consistency of the Draft Sustainability Appraisal. For example, in relation to the ‘economy and employment’ criterion, the Council scores the site as +2, but it is not clear why this is the case, as the allocation does not propose economic uses. It may be that the proposed primary school will generate a limited quantum of new jobs. However, other proposed allocations also envisage the provision of a primary school and yet are not awarded a positive score in relation to this criterion. (also summarised under evidence base).

Query why this site is being progressed when the planning history indicates that the Council does not consider it to represent a

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sustainable location (application 15/01176/OUT refers). Less constrained and more suitable sites exist within the Borough.



Detailed comments made ion the SA scoring:

• Climate Change (SA1) This score is derived from the overall score measured against the indictors set out in the Transport Accessibility Assessment (2017). There is a difference in scoring between 2010 and 2017 version of the Transport Accessibility Assessment. Circumstances have not changed significantly, therefore no justification for the divergence in scoring (2010: -2.5, compared to 2017 score of 0. It is considered appropriate to apply the 2010 assessment scores, which would indicate the site should score 0 in line with the SA.

• Biodiversity (SA3) The site has some local ecological value potential as a UK Priority Habitat and grassland has been identified for reptile and great crested newts. . Any local impact on the ecology could be mitigated through implementation of the development. The site should therefore be scored -1 in line with the Council’s SA.

• Groundwater source protection one (SA7a) Regional Agricultural Land Classification Map, the site is Grade 3 agricultural land. It is not within a Source Protection Zone and is not constrained by waste considerations. A small section at the northern boundary is located on mineral deposits but this is unlikely to constrain development. In line with Council’s SA, the site should be scored -2.

• Economy and employment (SA9) The Local Plan identifies a school will be delivered as part of the allocation, and it is agreed that this is an employment generating element of the scheme. However, for consistency, this benefit should result in the same scoring as attributed to Hayley Green, which also proposes a school, i.e. zero (and is reflected in the revised SA scoring or Parkview Farm).

• Revised overall SA score This should score -17 instead of the current -20.

There are multiple ownerships within the suite which could affect comprehensive development and timing. Other alternative sites within the restrictions should be considered such as Parkview Farm.

The footnote for the Policy set out in the Draft Local Plan indicate that the:

‘Total final number to be subject to further consideration of the

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impacts on the heritage assets’

At this stage, there is no certainty that the number of dwellings indicated in the Local Plan can be delivered. Alternative/additional sites should therefore be considered to ensure the Council is able to meet its housing need.

A previous application (14/01333/OUT) was refused on parts site for 88 dwellings. The subsequent appeal (PINS Ref: APP/R0335/W/15/3137269) was dismissed primarily on the grounds of unacceptable visual and landscape effects of the development which would not be mitigated by landscaping or the provision of some open space.

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Responses to Section: 6.6/Policy LP7. Land at Hayley Green.





Environment Agency (ID1261) Refer to comments on the sequential test and Sustainability Appraisal in relation to Policies LP3 and LP6.

Site is at flood risk but there are no requirements in Policy LP7 addressing this. Should the site pass the sequential test, Policy LP7 must refer to need for a FRA and the sequential approach locating all built development in Flood Zone 1. Without this, Policy LP7 would be unsound.

Amend Policy LP7 including need for a technical investigation and assessment of flooding (included in Policies LP4 & LP5 which are not at risk of flooding). Policy LP7 should specifically require all built development to be in Flood Zone 1, which ensures policy reflects Objectives B&D.

Provided site passes the sequential test, impact of climate change can be addressed by providing additional flood storage within the site, contributing towards Objectives B&D.



Warfield Parish Council (ID670, 674)

Concerned about location of proposed schools (and evidence to support their location). Development considered likely to only support a half form entry and is a short distance from two other proposed schools (Area 1 of Warfield SALP and Winkfield Row). Considers no evidence of sufficient demand based upon the proposed development at Hayley Green.

Warfield Parish Council (ID674) Notes Policy is based on concept in emerging Warfield Neighbourhood Plan.

Binfield Parish Council (ID259) Opposed to infill development when there are better suited strategic sites nearby.

Binfield Parish Council (ID259) There will be increased traffic flows along Forest Road through Binfield from this development.




Noted.


Development would bring additional strain on the already overburdened infrastructure.

Requests detail of the type of proposed housing, that there would be

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entry level homes for rent and sale, and that this would not be transferred under licence to another area.

No indication of any proposed additional employment on the above site.

No detailed information about the scale and sort of facilities to be provided. Proposed development falls below the threshold to provide on site infrastructure such as community facilities No plans for any built retail, leisure and other commercial development and no gain to the local community.

Requests more detail relating to the measures to mitigate the development’s impact on roads and encourage sustainable modes of transport as the new homes will impact the Forest Road and surrounding area.

The proposals will bring further strain on the inadequate sewerage and surface water system, as existing sites suffer from raw sewerage escaping from this system

Proposals include provision of an on-site primary school. Query justification for school when housing is below 600 units. Are there plans for a ‘creep’ in numbers in future years, thus asking the community to take more housing with nothing in return?

Limited information provided in relation to climate change mitigation and adaptation, conservation and enhancement of the surrounding landscape.



Scanlon (ID152), Murphy Proposals (and the concept plan) do not accord/ are incompatible (ID627, 628, 651), Tuffley with draft BFLP Policies LP1, LP12, LP13, and LP18 in relation to (ID986), Tuffley (ID1002), protecting and enhancing landscape assets, landscape character, Glennerster (ID1152), local character and distinctiveness and safeguarding amenity of Glennerster (ID1169), Gaw existing settlements. References to specific criteria: LP1 (iii), (iv), (ID1390, 1397) (vi), (viii), (ix) & LP12 (i), (ii), (iii) and (iv). Reference to not respecting

clay farmland landscape (SA objective SA4a). Vinson (ID177) Erosion of strategic gap detracts from communities having their own

identity and local distinctiveness. Vinson (ID343); Murphy (ID625, Plans for Cluster 7 are not ‘smaller scale opportunities for 628, 651), Tuffley (ID986), development through infilling and changes of use’ as stated in Tuffley (ID1002), Glennerster paragraph 5.11 of Overarching Spatial Strategy, which seeks to (ID1152), Gaw (ID1390, 1397) maintain the identity and integrity of smaller settlements. Reference

to Design SPD (Edge of Settlement/ Backland’ guidance), Character Areas SPD (chapter 4) and Landscape Character Assessment (all refer to smaller scale).

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Consider backland development should be subordinate, only occupy a minor proportion of the block in which it is sited. Para. 6.25 refers to context of site, defining characteristics of surrounding area to guide the appropriate density. Not considered proposed density consistent with character of Hayley Green.

Gorlowski (ID470), Phillips Concerns about development in this area of strong history/rural (ID538), Glennerster (ID1169), settings etc. Residents choose to live in a peaceful/ green natural Phillips (ID1311) part of the UK, with access to countryside and quieter out of town

location. Proposed development will ruin the green setting of Hayley Green village (BFLP cited saying site is important to setting of Hayley Green). Consider the heritage of Hayley Green village. Sacrifice easy access to amenities, public transport for advantages of living in small village, which will be lost if site developed.

Norman (ID634) Oppose building on green fields (quotes Hayley Green Residents Group residents questionnaire in 2015: 72% against; 6% support)

Murphy (ID628), Gaw (ID1389) Contradiction between Housing Background Paper ‘Recommended Approach: Basis of Allocation’ (land progressively more rural from Forest Road; especially land north/ west) and current version of some evidence base documents/ concept plan (eastern side as rural edge). Reference to BFC response to draft Warfield Neighbourhood Plan Reg 14 consultation which provided emerging Landscape Sensitivity Appraisal findings. References to Bracknell Road edge and need for transition between edge of village and rural edge of Warfield. Response to WNP seen to reflect Housing Background Paper. Concept Plan should be revised accordingly.

Murphy (ID628) Concept plan does not ensure ‘landscape character and sensitivity are fully considered’ or ‘strengthen and enhance landscape character and local distinctiveness’ (para. 11.2.6 & 11.2.7).

Murphy (ID628), Murphy (ID788)

Hayley Green is a significant landscape and visual amenity asset for the wider area (very few in Warfield). Rural character reflects unique east Berkshire countryside.

Murphy (ID651) Conflict between Housing Background Paper (p.178) which is taken from ‘Sensitivity to development’ from Landscape Sensitivity Appraisal (p. 300) and the conclusions of the Housing document in relation to LP7. Considers statement in Landscape Sensitivity Appraisal been given undue weight and not supported by policies map or OS maps – countryside is to the north of Hayley Green. North of site is rural, while west side is less ‘groomed’ and more naturally rural. Not captured in Appraisal. But Housing Background Paper: basis of allocation does, as does Council’s response on the Reg 14 Warfield NP.

Murphy (ID651) Landscape Sensitivity Appraisal does capture the landscape value of the whole cluster; reflected in BFLP section 6.6 first paragraph.

Murphy (ID651) Existing field patterns are the same as shown by hedge lines on OS map dating from 1856. Reflects agricultural heritage of site which would be lost.

Murphy (ID651) Strategic gaps evidence in Landscape Character Assessment (2015) does not take account of proposed allocation of land north of Forest Road, so there are no recommendations or policy guidance for this.

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This should ideally be reviewed. Murphy (ID788) Although Hayley Green is a now a settlement area, its fields and

hedges form an important link between countryside sites such as Hayley Green Woods and the extensive Green Belt area just north of the village.

Murphy (ID651) WAR15 previously rubble-strewn field, current landscape status reward for landowner efforts. Represents what could be achieved across whole site and reminder of what is to be lost if LP7 goes ahead. Point also summarised under Evidence Base – Landscape Sensitivity Appraisal.

CHARACTER

Taylor (ID51), Scanlon (ID152), Scale of development out of keeping with existing hamlets (Hayley Dacombe (ID325), Gorlowski Green); village will end up being a suburb/ dormitory estate of (ID470), Jarvis (ID488), Phillips Bracknell. Area being over-developed to extent unique character and (ID538), Murphy (ID628); heritage will be lost. Will triple size of village/ twice as many new Grinney (ID738), Wallen homes as existing. Inconsiderate to local area. Over-development in (ID826), Richardson (ID854, rural location. Will urbanise area with street lighting. Risk of 1496), Tuffley (ID987, 986), substantial detrimental change. Tuffley (ID1002, 1003), Glennerster (ID1152), Glennerster (ID1162), Menon (ID1535), Phillips (ID1311) Clark (ID145), Murphy (ID628, Development out of keeping with a ribbon form of development. 651); Grinney (ID738), Tuffley Existing village small linear settlement. References to settlement (ID986), Tuffley (ID1002), being ‘F’ formed by Forest Road with Goose Corner and Hayley Glennerster (ID1152), Phillips Green road. (ID1311) Dacombe (ID325), Bruen Development would be on last remaining open green space in (ID334), Norman (ID634), village; would remove the ‘green’ from Hayley Green. Green fields Murphy (ID628, 651), Grinney and hedgerows need to be preserved to maintain intrinsic rural (ID738), Tuffley (ID990, 986), character and setting of this beautiful area in England. Specific Tuffley (ID1006, 1002), reference to: field at the corner of Forest Road and Cricketers Lane, Glennerster (ID1136, 1152), land behind Cricketers Pub (towards Hayley Green). Currently used Glennerster (ID1162), Gaw as grazing. Last visible signs of green in Warfield. Will change the (ID1390) character of this village for ever; cease to be a rural area. Bruen (ID332), Murphy (ID628, Proposed housing density out of character with existing village/ 651), Wallen (ID826), Collings hamlet feel. Higher density compared to Winkfield Row. Higher (ID1071, 1089) density than Warfield Neighbourhood Plan because of addition of

primary school. This large school site will further impact the local character and landscapes for existing residents.

Hobbs (ID1095), Glennerster (ID1152)

Two-form entry primary school is over development in this rural location.

Wright (ID469), Tuffley (ID986), Concerns over positioning of primary school which disregards local Tuffley (ID1002), Glennerster heritage. Some state would be better sited in midst of proposed (ID1152) housing away from busy Forest Road. Access via Cricketers Lane is

very narrow and impractical. One reference to “former Warfield CE Primary School is included in the xxxx”.

Wright (ID469), Gaw (ID1389, Concerns over positioning of open green space.

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1390) Murphy (ID628), Open space in the east will have detrimental impact on new

residents (few option for creating open space around their home) and an overwhelmingly negative impact on existing residents losing green space currently surrounded by. Important to setting of Hayley Green and a non-designated heritage asset.

Gorlowski (ID470) Concerns that once traditional community destroyed cannot be restored.

Gorlowski (ID470) Old architecture (schools/ churches etc) will be overlooked/ swamped by new development (which is considered to have a shorter life expectancy).

Murphy (ID628) Questions how well-designed development will be delivered. Refers to Housing Background Paper: Basis of Allocation, specifically “would represent a significant extension of the existing settlement, much consideration needs to be given to how the development can be designed to integrate with the existing development….”

Murphy (ID628, 651), Tuffley (ID986), Tuffley (ID1002), Glennerster (ID1152), Gaw (ID1390)

If concept plan is unchanged, need robust policy guidance (no BFC policy guidance as of yet) that respects the character and form of existing linear-form villages (acknowledging linear settlements face road and have open land behind them). How evolved over centuries is fundamental characteristic.

Murphy (ID651) Cites BFC response to the Reg 14 Warfield Neighbourhood Plan, in relation to the emerging Landscape Sensitivity Appraisal. Quotes include “development parcels on this [Bracknell Road] edge … will urbanise Bracknell Road and completely change its character. Consideration should be given to the edge being more transitional between the edge of the village and the rural edge of Warfield.”

Tuffley (ID1008) Supportive of the new homes being self build and custom build properties.

Tuffley (ID1007), Phillips (ID1311)

New development should reinforce and respect the local character. Reference to varying collection of houses in different styles, character and sizes. Concerns new development will not be sympathetic to the preservation of this unique character. Concerns about aesthetic impacts as well as on traditional settlement pattern and sense of community. One reference to nearly all properties in Hayley Green being bungalows.

Collings (ID1071, 1089) The Draft WNP at least proposes a buffer of open green space between the new development and existing residents of the B3034 Forest Road, similar to the treatment of West End Lane in the Warfield SPD. BFC’s proposed plan does not appear to include a buffer which will do nothing ‘to maintain the local character and landscapes for existing residents’, contrary to Policy LP1 iii) of this Plan.

Collings (ID1071, 1089) The proposals are opposed to Policy LP18 (Design) (v) – ensure that new development…respects local heritage and patterns of development.

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Scanlon (ID152), Jarvis (ID488), Gunn (ID1159), Fazey-Gunn (ID1239)

Impact upon wildlife (badgers, foxes, deer, owls, red kites) through noise, pollution, light and concrete.

Bruen (ID334) Green spaces will be seriously eroded. Murphy (ID789) BFLP section 17.1.5 refers to needing ecological surveys in areas

where reasonable likelihood of protected habitats and other listed species. Several bird species listed in NERC Act or BFC BAP are either resident (House sparrow, Dunnock, Starling, Song thrush) or regular visitors (Bullfinch), although latter declined over last 10 years. Data available to support this.

Murphy (ID628, 650), Murphy (ID789)

Proposals contrary to Policy LP36: Biodiversity (especially with development concentrated to west of site). Evidence used to justify placement of housing is poor/ subjective. IDP refers to site as being ‘ecologically rich’; add oak trees and grassland to text. Underlines loss developing site will inflict, regardless of mitigation. Current vegetation cannot be ripped out and replanted. Preservation and conservation with enhancement should be guiding principle.

Murphy (ID628) Consider site would be suitable as a SANG given proximity to eastern end of SA9, Area 3.

Murphy (ID628) Question why project-level HRA would influence final layout (para. 6.48) unless relevant area made into SANG?

Murphy (ID628, 651), Murphy Questions why development is focused in the west and open space (ID788), Tuffley (ID986), Tuffley in the east outside of proposed settlement boundary, alienated from (ID1002), Gaw (ID1390) settlement. Open space being outside settlement limits options at

planning application stage. Evidence base supporting this position is considered to be influenced by a variety of unsupported/ inadequately evidenced statements. Contrast to Housing Background Paper (p.182) which states land becomes progressively more rural the greater the distance from Forest Road (especially the north and western parts). Also quotes that much consideration is needed. Concept plan and proposed settlement boundary are contrary to this. Need to consider where countryside actually lies in relation to Hayley Green. Should be thoroughly reviewed.

“Now” documented error in the flood risk assessments and the requirement for further assessment in terms of flooding, ecology, and Habitats regulations indicate that settlement boundaries should include the full area of the cluster as evidence base indicate all parts of Hayley Green have value.

Murphy (ID628) Allocation of cluster threatens connectivity, contrary to LP1, LP12, LP36 and LP38.


Location of proposed development as per the concept plan (dense development in part of site and marginalising green space on other), risks losing valuable sites for biodiversity and ecological potential, fragmenting habitats and losing connectivity. Threatens to worsen inevitable losses from alienation of greenfield agricultural land because of reliance on flawed evidence base. Existing plan would

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result in countryside being lost that is important in the wider context of the countryside (and associated biodiversity) protection within the borough.

Murphy (ID650, 651) Expand Hayley Green Woods northwards into land at LP7 as LNR, OPSV or SANG. Would contribute to Green Infrastructure and create a visible gap, preserve landscape character and visual amenity of Hayley Green for wider area and passers by.

Murphy (ID650), Tuffley (ID986), Tuffley (ID1002), Gaw (ID1390)

Unacceptable for village to lose its fields and be directed to an off-site SANG (Frost Folly) over 1.5 miles away. Leads to increase in car use with associated pollution and health impacts.


Will reduce substantially green corridor connection than present. Preservation and conservation with enhancement should be guiding principle; avoid having to replant. Most species have fluid ranges and cannot survive in isolated populations.

Murphy (ID650) Other points of Green Infrastructure connection: Bull Brook LNR, Hayley Green Woods, and the woodland bordering Hayley Green (lane) and up Malt Hill (Warfield House) connecting towards the Cut woodland at Wane Bridge, and woodland of Cricketer’s Lane. References provided in relation to IDP Green Infrastructure text.

Murphy (ID651) New trees in LP7, should consider oak trees in WAR13 as a suitable location for heritage aspect and connectivity with woodland beyond Cluster 7.

Murphy (ID651) Majority of cluster mapped as a gap in woodland and grassland networks, but contains both habitats. Importance of site as green infrastructure – green spaces for residents and as a corridor.

Murphy (ID651) Green gap reflected in enlargement of Hayley Green Woods (LWS) to Westmorland Park and Bull Brook (LNR). Suggests extending LNR north of Forest Road in the Area 3 boundary but maintain Hayley Green in countryside making LNR ‘bigger, better, better-connected’. Contribute to WFD objectives. More ‘blue skies’ – not developing would allow preservation of trees/ woodland/ hedgerows/ grassland.

Murphy (ID651) Detailed comments provided on woodland and grassland in the cluster in relation to improving green infrastructure connections, value of overall habitat and ecological network. Reference to old OS maps showing longevity of hedgerows/ woodland. Provide local heritage as well as Green Infrastructure. Reference to oak trees and woodland belts in WAR13/ WAR14. Grasslands used for grazing; no chemicals so easier to restore habitats than cultivated fields – opportunity to enhance GI in area. Proximity to Bull Brook and Cut referenced – support WFD.

Glennerster (ID1136 & 1149) Open space/ green fields in Hayley Green valuable to both residents locally and of other communities and visitors. Need protecting in the area.

Sturges (ID1254, 1301) Supportive of village green concept shown on first map which would help keep village feel and be somewhere for residents to meet; this has now disappeared.

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Taylor (ID51) Policies should enable infrastructure to be provided, whilst safeguarding and enhancing the environment and taking climate change.

Reeves (ID98), Clark (ID145), Existing drainage and flooding issues (groundwater, surface and Vinson (ID177), Phillips (ID538), fluvial) in the area/increased flood risk (with overlap), without Murphy (ID628), Grinney proposed development. Affects most of the site. Loss of greenfield (ID738), Tuffley (ID986), Tuffley ‘sink land’ not addressed. Fields waterlogged all winter and a fair bit (ID1002), Glennerster (ID1149, of summer. Large estate will increase flooding in the area/ increase 1152), Glennerster (ID1167), surface water and groundwater flood risk. Area notoriously ‘soggy’. Phillips (ID1311) Roads flood after heavy rainfall. Reference to Hayley Green Woods

flooding, and increase of woodland users having a significant effect on the area.

Vinson (ID177), Murphy (ID628, Impact to sewerage system (already under strain). Issues of foul 627, 650, 651), Tuffley (ID988), flooding events (comments about regular problems with sewage) in Tuffley (ID1004), Glennerster this low lying area. Thames Water need to factor in improvements to (ID1152), Maidens Green the network before planning; pipes will need to be re-laid to cope. Society (ID1155), Glennerster Considered Thames Water will need to plan for economy/ efficiency (ID1167) in terms of what/ when upgrade needed to serve sites (which could

deliver at different times). Concern over potential further delay in allocating work to the investment programme. Concerns about coordinating upgrades with LP6 too, which also suffers from shared inadequacies (225+450+525 in; 450 out) at junction at Cricketers Lane/ Bracknell Road. Cracked waterpipes on far side of Malt Hill at Wane Bridge. Considered problems will only get worse with proposed development.

Vinton (ID347), Murphy (ID650) Winkfield area frequently flooded (land primarily clay, drainage poor and flash flooding evident) with adverse impact on sewerage system – number of sites that suffer from raw sewerage escaping into the system in Hayley Green. Area wide inadequacy issue, shared with Winkfield Row.

Phillips (ID538) Consider likely that green areas as part of development would be unusable for most of the year due to drainage.

Phillips (ID539), Ward (ID1250) Drains have been overflowing into the roads. Hayley Green wood has been completed flooded (near Winkfield Row site). Cricketers Lane has also been closed due to flooding. Following flooding in weeks at end of March/ early April 2018.

Murphy (ID628, 650), Grinney Proposal (in combination with LP6 and SA9) will increase pollution (ID738), Tuffley (ID986), Tuffley (air quality and noise) and associated health impacts, including in (ID1002), Phillips (ID1311) relation to school traffic from outside area associated with new

primary school. Murphy (ID628, 651), Tuffley Creation of suitable SuDS may increase costs and needs to be (ID986), Tuffley (ID1002), integrated with wastewater upgrades since it is a recurrent issue. Glennerster (ID1152) Considered to threaten cost and timescale of development delivery.

SuDS should allow site design that benefits existing and new residents, which green space near/around homes.

Murphy (ID650, 651) Premature to comment with Level 2 SFRA yet to be done. Draft SFRA maps flood risks on a provisional basis – whole-site data

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not linked directly to flood risk areas. North east of site in FZ3; remainder mostly at risk of surface or groundwater flooding, or both. Hope flood risk can be accommodated in a site design that benefits entire community with open space around them.

Murphy (ID650, 651) Concerns regarding the scale of the wastewater upgrade required by Thames Water. Currently just grinding out roots and relining the sewage pipe beyond Wane Bridge. Have verbally acknowledged 225+450+525 input entering junction exceeds 450 pipe exiting. FOI quoted referring to 5 separate foul flood events/ effluent flood events between Jan 2013 and 2017 (dates of events provided).

Concerns over ability to cope with allocations LP6, LP7 and other permissions in area – issues should be tackled together (especially as new Thames Water charging structure (2018/19) does not require additional network costs to be apportioned on a site basis. Problem in March 2017 at Goose Corner Hayley Green led to further work at junction of Wane Bridge.

Murphy (ID651) Questions extent to which current flood risk evidence has been used to inform decisions about site layout/ settlement boundary. Considers mistake in SFRA evidence (see Evidence Base summary).

TRANSPORT

Taylor (ID51), Green (ID96), Concerns regarding highway safety (including of cyclists, Clark (ID145), Scanlon (ID152), pedestrians), local roads already congested (queuing times of Lowe (ID153); Bruen (ID335), approx. 10 mins suggested), rural road network will not cope with Wright (ID469), Jarvis (ID488), scale of traffic increase (para. 19.1.6), surrounding road Phillips (ID538), Murphy (ID628, infrastructure, noise and pollution, documents wrong to say no traffic 644, 650, 651), Grinney hot spots/ choke points. (Specific roads/junctions referred to in (ID738), Tuffley (ID986), Tuffley comments include: intersection between the B3034 (Forest Road) (ID1002), Collings (ID1071), and the A330 (Winkfield Road); Braziers Lane; Strawberry Hill, Hobbs (ID1095), Glennerster Hayley Green Road; Cricketers Lane). (ID1136, 1152), Maidens Green Additional cars from new development will cause problems, despite Society (ID1155), Gunn planned junction enhancements and cause congestion/ additional (ID1159), Fazey-Gunn travel time. Forest Road and Winkfield Row already used as a cut (ID1239), Ward (ID1250), through. Will create queues. Enhancements are limited given scale Sturges (ID1254, 1301), Phillips of increased traffic that can be expected. (ID1311), Gaw (ID1390) Reference to roads in area all being single lane traffic with no room

to widen – no amount of junction improvements can change this. No mention about improving roads to deal with more traffic. Quality will have to be better.

Dacombe (ID325), Murphy Junctions highlighted for improvement have very little space around (ID628, 644, 650, 651), them for improvement. No details of improvements given (concerns Glennerster (ID1152), Maidens raised if this was traffic lights – stationery traffic increasing noise and Green Society (ID1155), Gunn pollution; or if roundabouts). Anticipated to absorb the extra traffic (ID1159), Fazey-Gunn not just from LP7 and LP6 but all extra traffic in the area (including (ID1239), Phillips (ID1311) motorway bound e.g. Heathrow staff). Question how up-to-date

modelling is of Forest Road. Enhancements seem unlikely to cope, especially as sole strategic improvement proposed. Forest Road still a small rural B-road. Single land roads – no way to improve to

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anything better or increase width of road. Willshire (ID136), Dacombe (ID325), Jarvis (ID488), Murphy (ID628, 651), Tuffley (ID986), Tuffley (ID1002), Glennerster (ID1152), Ward (ID1250), Phillips (ID1311)

What proposals are in place (including by RBWM) to improve junctions and road structures on Forest Road and surrounding Hayley Green (taking account of Woodhurst Park development, SA9, LP6, traffic coming north up Locks Ride from developments on London Road, Binfield)? Need to consider everything that will feed onto and use Forest Road. Existing road junctions dangerous. Suggested enhancements unlikely to prove adequate.

Phillips (ID538); Murphy Access point on Hayley Green [Road] wholly inappropriate. Road (ID628), Wallen (ID826), Tuffley already congested with nursery traffic and parked vehicles (ID986), Tuffley (ID1002), (especially at Forest Road end), and is narrow (example provided is Collings (ID1071), Hobbs too narrow for a lorry and car to pass each other). Would require (ID1095), Glennerster (ID1152), removal of historical mature hedge boundary (ref to LP18 iii). Menon (ID1535), Gunn Reference to Malt Hill/ Hayley Green road being potential accident (ID1159), Warfield Environment black spot. Would result in queues. Site bounded by four roads – Group (ID1192), Fazey-Gunn unclear why one of smaller, narrower roads with on-street parking (ID1239) has been chosen. Road cannot support proposed number of houses.

Site bounded by 4 road yet only a single access indicated. Collings (ID1089), Hobbs (ID1095)

Both BFC and the Draft WNP are promoting access onto roads which are unsuitable for large-scale development.

• The Draft WNP potentially reduces the impact of traffic onto the roads by proposing more than one access into/out of the development, though the one onto Cricketers Lane is likely to harm its rural character.

• The BFC plan has all access onto Hayley Green (between the B3022 Bracknell Road and the B3034 Forest Road) which is unsuitable for that purpose and will certainly harm its character.

• The Warfield SPD recommends access onto Harvest Ride for most of the current new development in Warfield; at least that road was built at the same time as the Whitegrove development and so can be considered fit-for-purpose.

Sturges (ID1254, 1301) Only access point seems to be in Gypsy Lane, very close to a nursery school. Considered children but not their safety.

Wallen (ID826) Hayley Green road is frequently used by horses. Scanlon (ID152), Phillips Development not located as to reduce the need to travel, scored (ID538), Murphy (ID627, 628, bottom in transport accessibility, few improvements to discourage 651), Tuffley (ID986), Tuffley car use. (ID1002), Glennerster (ID1149), Gaw (ID1392) Lowe (ID153), Wright (ID469), Jarvis (ID488), Phillips (ID538), Sturges (ID1254, 1301), Phillips (ID1311), Gaw (ID1390)

Concerns regarding location of proposed school at junction of Forest Road/Cricketers Lane, and highway safety (road is busy in rush hour, narrow footpaths, Cricketers Lane too narrow to support additional traffic, difficult to see from concept plan where the access to the school will be). Will be very very noisy from all traffic from the new development in Winkfield Row. Concerns about pedestrian safety getting to the school along Forest Road, including that of children. Reference to location being on a 40mph road with a junction that requires improvement.

Green (ID96), Grinney (ID738), Addition of two new primary schools (Hayley Green and Winkfield

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Ward (ID1250) Row) will increase traffic on Forest Road, which will not be able to cope.

Vinson (ID177), Dacombe Primary school will add to existing traffic (because will draw in a (ID325), Phillips (ID538), larger catchment area that just Hayley Green), road network will not Murphy (ID628), Grinney cope. Concerns over parking associated with school run, including (ID738), Collings (ID1071, parking where will be possible to access proposed public footpath. 1089), Blackburn (ID1102), Children from outside area will use schools, increasing traffic in area Phillips (ID1311) and pollution. Parking proposals unclear. Vinson (ID183), Murphy (ID628) Sites have poor scores on transport, very limited accessibility, and

do not meet Policy LP1 in terms of a location reducing the need to travel and minimal reliance on private car.

Dacombe (ID325), Bruen Concerns area poorly served by public transport and no visible (ID335), Jarvis (ID488), Phillips provision in the plan for an increase in public transport or promoting (ID538), Grinney (ID738), fewer cars. Transport measures proposed will have little or no Murphy (ID627, 628, 644, 647, effect. No alternative public transport systems in the northern 650, 651), Tuffley (ID986), parishes. Tuffley (ID1002), Hobbs IDP states there is a ‘need’ but only ‘potential support’ stated. (ID1095), Maidens Green measures provisional and unlike to reduce use of cars for daily Society (ID1155), Ward journeys. Travel options will still be limited (Draft SA score for (ID1250), Phillips (ID1311), Objective SA17). Current bus service <1 hourly would need Gaw (ID1389) improvements to all it for use for schools/ commuting. Questions

how long subsidies would last. Existing bus services considered inadequate. Reference to policy LP47 - if unmitigated adverse impacts acceptable, could result in no provision of alternative travel options except the car leading to congestion/pollution.

Dacombe (ID325); Bruen Speed limits on Forest Road and past Lambrook School are not (ID335), Phillips (ID538), obeyed or enforced. Traffic calming solutions needed, and to be Phillips (ID1311) enforced. Walking along Forest Road considered dangerous. Lack of

existing safety for pedestrians. Phillips (ID538) Existing parked cars along Hayley Green Road will make things

worse with additional traffic at junction of Forest Road. Associated increase in pollution.

Phillips (ID538); Murphy (ID627, Proposed development would create extra (approx.470) cars on 628, 651), Grinney (ID738), roads in village, and new residents will commute. Will be little choice

for new residents to access amenities locally, so no other than to use cars (mitigation unlikely to meet impact of proposal). SA objective SA17 ranking of site is acknowledgement new residents will use cars.

Phillips (ID538), Phillips (ID1311)

Roads and pavements need widening and improving (pavements uneven at present), but this would encroach on current properties along roads. Need safe pedestrian crossings.

Phillips (ID539) BFC issued letter to local residents (4/4/18 – provided letter in response) stating cross roads of Malt Hill and Hayley Green Road require safety improvements following a number of accidents in recent years (work undertaken in early April 2018). Concern that potential development would increase number of cars using this junction.

Murphy (ID628, 644), Proposal contrary to LP46. Requirements of LP45, LP46 and LP47 unlikely to be met by Policy LP7, reflected in draft SA score for

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objectives SA1 and SA17. Scale of improvements/ enhancements to meet Policy LP45-LP47 and meet sustainability objectives mean unlikely to be able to mitigate impact of Policy LP7. Policy LP45 and supporting text not well related to IDP or SA17 scoring for LP7.

Murphy (ID628) Proposals will have a knock on impact on RBWM. Question whether this has been assessed using robust up-to-date data.

Murphy (ID627, 628, 651), Hobbs (ID1095)

Question whether cumulative impact of developments (LP7, LP6 and SA9) have been assessed using robust up-to-date data/ traffic flows have considered them.

Murphy (ID628, 644, 650, 651), Developer funded enhancements to shared cycle/ footpath networks Tuffley (ID986), Tuffley and bus services are all provisional and limited in scope. Only shown (ID1002) on a site basis. Masterplanning needed – what will guide ‘further

improvements to the network within 3km’ cited in IDP (only as ‘potential’). Indications of routes are vague, especially regarding wider network. Implications for properties fronting relevant roads unclear. Shared route (pedestrian and cycling)? Shared route should be comparable to Harvest Ride/ County Lane and not Westmorland Park if pedestrians are not be deterred from using it. Constraints to widening on Forest Road, busy, ditches. Connections to existing and planned settlements/ network unclear. Residents should be given opportunity to comment on proposed routes ahead of BFLP being finalised.

Murphy (ID628) Railways stations are distant and facilities for cycles limited/non-existent.

Murphy (ID628) Policy LP45 only helps to meet climate change objectives if developments can provide viable alternative transport options (para. 18.2.7).

Murphy (ID628) Accessibility shortcomings of the site reflected in SA score for objectives SA1, SA15, SA16 and SA17.

Glennerster (ID1149) Idea that residents in the borough will only want to live, work and play in the area is ludicrous. Residents of Warfield will travel will be by cars.

Maidens Green Society (ID1155)

Isolated semi-rural site – car travel required – more traffic pushed towards Maidens Green crossroads. Possibility of more traffic from Winkfield Row site, and other planned developments (Harvest Ride, Blue Mountain, Amen Corner). References travel to Heathrow, Maidenhead M4/ M40, Slough via B3022 Bracknell Road.

Phillips (ID1311) Considers existing evidence does not sufficiently shown how exactly infrastructure can support additional village and commuting traffic.

INFRASTRUCTURE

Scanlon (ID152), Murphy No realistic plans to provide services or facilities to make Hayley (ID627, 628, 644), Grinney Green a sustainable community/ north of the borough (draft SA (ID738), Tuffley (ID986), Tuffley indicates no new community facilities – developers would contribute (ID1002), Blackburn (ID1103), to hub elsewhere). Only infrastructure is a new school. Will not Glennerster (ID1149, 1152), enhance the residents of Hayley Green. Overwhelming pressure on Menon (ID1535), Gaw (ID1389) existing. IDP will still leave people without most local services and

facilities and reliant on cars. (Scoring of SA objectives (Objectives

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SA6a, SA6b, SA7a and especially SA1, SA15, SA16, SA17 indicates Policy LP7 will not create a sustainable community).

Scanlon (ID152), Murphy (ID628), Gaw (ID1390)

Existing infrastructure inadequate to support existing residents needs, and proposed development. Residents may have to travel further afield.

Dacombe (ID325), Phillips (ID1311)

Existing infrastructure cannot cope with the increase in traffic etc. that this will bring.

Murphy (ID650) Questions local road network junction improvements. Added to comments under Transport above.

Scanlon (ID152), Vinson Lack of existing medical/health facilities – where would new (ID177), Jarvis (ID488), Phillips residents register with a doctor or dentist? People will need to drive (ID538), Tuffley (ID986), Tuffley to these services. No additional medical/ dental/ retail facilities (ID1002), Glennerster (ID1149), proposed in Hayley Green, or at Whitegrove or closer in IDP. Will Phillips (ID1311) lead to over-burdening facilities at Whitegrove. Comments relating

to difficulty booking appointments. Phillips (ID538), Phillips (ID1311)

No local shop, retail or grocery provision. Concerns regarding capacity of existing Tesco at Whitegrove to cope. Not considered practical to walk/ cycle there and get necessary groceries for a few days, or a week. Concerns that getting large items delivered would add to traffic problem, and unacceptable to average family with children and full time jobs.

Phillips (ID1311) Concerns regarding access to a post office, which as existing requires using Bracknell Town Centre. Would require use of car; bus services and waiting on Forest Road not considered suitable.

Scanlon (ID152), Murphy Proposed off site open space to compensate for loss of fields in (ID628), Tuffley (ID986), Tuffley Hayley Green indicates a disregard for local heritage of the village. (ID1002), Gaw (ID1390) Loss of existing amenity for residents (including setting of their

village and part of their daily lives) and will lead to more car use (knock on pollution and health impacts). Will have devastating effect on village.

Murphy (ID651) Perceived deficit of open spaces seems odd given site in countryside. Questions if footpath network of countryside and Green Belt considered.

Jarvis (ID488), Murphy (ID627, Question the catchment for the new primary school (development of 628, 650), Wallen (ID826), 235 not large enough to trigger; unwarranted, over-catering), Tuffley (ID986), Tuffley particularly as so close to 4 existing schools (Warfield (2 sites), (ID1002), Blackburn (ID1102), Whitegrove and St Marys Winkfield). Reference to IDP (pg. 68; Ward (ID1250, 1252), Phillips column 3) – considered likely school will serve development (ID1311), Gaw (ID1390) elsewhere, e.g. contribute to a second-form entry (which would

equate to increases in traffic on what will be a heavily congested commuter road, leading to associated congestion/pollution). Suggestions include one primary school to serve Hayley Green and Winkfield Row. Concerns over sustainability in terms of increase in school runs/ location unlikely to result in trips being by public transport. Contrary to LP1 (viii) (ix) and LP45. Alternative means of travel considered unlikely given location and large catchment. Disproportionately costly for developer.


Concerns over CIL payments needed for primary school (need 600+ homes) compared to the number of homes proposed (235). Questions whether this will result in increase in density and housing

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(flats/ apartments) with limited space. Gunn (ID1159), Fazey-Gunn (ID1239)

Provision of primary school laudable, but consider need is for local secondary schools.

Tuffley (ID986), Tuffley Concerns over wastewater infrastructure. Wastewater infrastructure (ID1002) Vinson (ID177), inadequate in Hayley Green (IDP confirms this), including foul Murphy (ID628, 627, 650) flooding events. Also affects Winkfield Row. Thames Water need to

factor in network improvements before planning. Constraints threaten delivery of site in timely manner. Detailed comments under Climate Change/ Environmental Sustainability section above.

Glennerster (ID1152) Flooding and Sewerage issues threaten delivery of affordable homes in a timely fashion.

Murphy (ID628), Gaw (ID1390, 1392)

Current policy wording of LP7 suggests there is ‘wriggle room’ with infrastructure provision (including affordable homes and necessary infrastructure) should developer costs and work increase. LP7 unlikely to be compliant with Policy LP9. Consider infrastructure improvements will require heavy investments which could impact on delivery of affordable housing.

Murphy (ID650), Richardson IDP suggests there are large number of separate infrastructure (ID854, 1496), Tuffley (ID986), delivery costs and some site-specific issues, which could mean cost Tuffley (ID1002) of development sufficiently high that will not be viable, or affordable

housing will be compromised. Timescales uncertain? LP7 smallest of ‘large sites’ so a lot of developer costs to absorb – considered likely to impact on viability and delivery of all required infrastructure improvements. Infrastructure issues could delay site delivery and package of measures bought forward.

Gaw (ID1392) Need provision of affordable homes to be where people can most easily reach facilities and workplaces. Location of Hayley Green does not reduce the need to travel.

Murphy (ID650) IDP references to footpaths and cycleways all conditional ‘schemes could include’ and ‘possible subsidies’. Will developers be coordinated so Hayley Green can link to Winkfield Row for example.

Comments also include where land will come from, implications for homeowners, why new paths only shown on a site basis and why there is no masterplanning. Added to comments under Transport above.

Murphy (ID651) Area provides network of paths and acts as a ‘rural gateway’ leading to countryside. Fields are working landscapes. Provide access and recreation.

Murphy (ID650, 651) IDP refers under early years to Multi-functional community centre/ hub. Appears many times under many potential uses but with no indication as to its potential location. Hub does not feature in policy LP7 or on concept plan. Concern that adding the building would increase the density on the remainder of the site; does developable area calculation include primary school? I.e. has school area been included in calculation of 30dph. Number of dwellings proposed does not trigger need.

Blackburn (ID1103) By treating Hayley Green, Mushroom Castle and Winkfield Row as separate allocations, not triggering the provision of new facilities and

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service improvements as each site well below 1,000 unit level (and even combined fall short of 1,000 units). Considers this bad news for local residents; significant increase in housing and impacts on existing infrastructure without any significant improvements.

OTHER MATTERS

Clark (ID145), Phillips (ID538), Murphy (ID628),

Comments about the Neighbourhood Plan process, and site promoted with local residents input. Should consider the Neighbourhood Plan and compromise and work with village to bring about best outcome. Conflict between draft Warfield Neighbourhood Plan concept plan and the draft BFLP concept plan. Newhurst Gardens appeal inspector stated proposals ‘in direct conflict with each other’. Need to be clear on relationship between them.

Murphy (ID628), Tuffley (ID986), Tuffley (ID1002), Glennerster (ID1149), Glennerster (ID1164), Gaw (ID1389)

Draft Warfield Neighbourhood Plan allocates land at Hayley Green because most sustainable location in Warfield. Draft Transport Accessibility Statement (Section 6; Table 10) ranked accessibility at 0. No other sites with this rating are proposed for allocation; no other Warfield site has this ranking. Flawed conclusion to allocate site.

Murphy (ID651) BFC evidence base shows Warfield Neighbourhood Plan assessment of site as most sustainable in Warfield is flawed. Reference to draft SA scores SA1, SA15, SA16, SA17.

Wallen (ID844) Should not consider Hayley Green site as not yet accepted and adopted in the Warfield Neighbourhood Plan.

Murphy (ID628, 651) Question why ‘at least 235 homes’ when all other allocation policies indicate a specific number. Residents argued against this number in Warfield Neighbourhood Plan partly on grounds of overdevelopment. Proposed number in excess of size and density of existing settlement.

Vinson (ID177), Vinson (ID343) The site does not offer a sustainable environment, sustainable transport or sustainable facilities, and does not fulfil the vision set out in para. 3.1 or the Sustainability Appraisal Results chart in the draft Sustainability Appraisal. Preference should be given to BRA sites based on the SA ratings.

Vinson (ID183, 184), Murphy (ID628), Tuffley (ID986), Tuffley (ID1002), Phillips (ID1311)

The development does not provide employment, existing and new allocations are distant, which means everyone has to commute out. Not directly accessible by public transport. Associated congestion and pollution. Noted primary school and potential community centre will provide employment opportunities, however concerns regarding skill set necessary, which may result in commuting staff and associated congestion/pollution.

Phillips (ID538) Desirable place to live, reflected by house prices. Likely potential new housing would sell fairly quickly creating huge profits to developer and BFC. Money driven process under banner of government housing targets.

Phillips (ID538) Considers that fewer new houses should be proposed by at least half (amount should be fewer than the current settlement size, not doubling the amount).

Murphy (ID628) Site should surely not be allocated, even in the face of pressures to build.

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Murphy (ID628) In terms of sustainability, one of worst locations proposed in draft BFLP (along with LP6).

Murphy (ID628, 651) LP7 not in alignment with vision; does not meet plan objectives D, F, G, H and I, and as currently designed compromises Objective B. Will not result in key Council Strategy of a self-reliant community.

Murphy (ID651) In Housing Background Paper – Recommended Approach (Basis of Allocation) – under spatial strategy. Endorses recognition that rural edge of cluster to the north, and north/western part of cluster recognised as particularly rural. Supports text acknowledging ‘significant extension of the existing settlement’ together with ‘consideration to be given to how the settlement can be designed to integrate with the existing settlement’. Sensitive guidance (along with LP1, LP12 and LP18) will be invaluable if site allocated. Considers ranking of objective SA3 overly optimistic regarding biodiversity loss.

Richardson (ID854, 1496), Potential land assembly issues that could delay bringing site forward.


Careful consideration of evidence base suggests that all parts of Hayley Green have value, which housing background paper does not always capture.

Blackburn (ID1102) Majority of site is greenfield – development on greenfield land should be avoided if suitable non-greenfield sites are available.

Murphy (ID625, 628, 650, 651), Drawing new settlement boundaries premature a) discrepancies in Tuffley (ID986), Tuffley evidence base documents i.e. Housing Background Paper: Basis of (ID1002), Gaw (ID1390, 1397) Allocation, b) preliminary/ incomplete evidence base (including error

in SFRA), c) absence of design policy and d) differences with Neighbourhood Plan (in relation to LP7). New settlement boundary through fields; not considered ‘strong and defensible’.

Considers some confusion regarding the settlement boundary, based on countryside lying to east of Hayley Green; OS map shows countryside to the north of the village with residential/school properties to the east. Considers allocation of Hayley Green inconsistent with para. 6.25 & 6.28 of the BFLP. Premature to indicate developable area boundaries in absence of complete information and appropriate design policy for some sites. Could be detrimental at planning/ final site design stage. If drawn, should include full cluster and final boundary confirmed in due course.



Paragraphs 6.44 to 6.49 As stated in paragraph 6.49, this site is in several different ownerships and it is very likely that this will significantly delay delivery of the site. This factor needs to be taken into account when considering the rate of delivery of housing from this site.


Does not meet all the criteria in Policy LP1, specifically:

(iii) requires… maintenance of local character and landscapes, (iv)

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requires… protection of area settings (viii) requires… development locations to reduce travel and (ix) requires… less reliance on car travel.

This is not a supportable location in highways term. Boyer on behalf of Jordan Strongly supports proposed allocation at Hayley Green in principle Construction (ID1360, 1362) welcome BFCs support for emerging allocation as also proposed in

Warfield Neighbourhood Plan (WNP), subject to comments raised. Boyer on behalf of Jordan Concerns about potential areas of conflict between proposed Construction (ID1360, 1362) allocation in draft BFLP and emerging Warfield Neighbourhood Plan

(WNP). Differences include allocation including Meadowbrook Montessori Pre-School and on-site in-kind provision of a primary school. WNP expected to be submitted imminently and made by end of 2018. Likely WNP will form part of development plan before emerging Local Plan. Cites policies in draft WNP. Consider the extent of the allocation should be amended to reflect the submission version of the WNP in due course in the interests of consistency

Boyer on behalf of Jordan Understand there is a covenant on Montessori land which restricts Construction (ID1362) its use for social and education purposes. Boyer on behalf of Jordan Question whether it is necessary to allocate site in BFLP when likely Construction (ID1362) WNP will be part of development plan by end of 2018. Boyer on behalf of Jordan WNP does not propose ‘additional educational facilities’ as evidence Construction (ID1362) base prepared has not identified a need for one. However IDP

requires on-site provision of 1FE primary school, with second form of entry to be paid for by other development. Area for primary school covers approximately 2.2ha. Therefore seek clarity on whether on-site primary school requirement in LP7 is necessary and/or justified; and the impact, if any, the proposal for on-site primary school provision has on WNP aspirations and development principles for the site.

Boyer on behalf of Jordan Information provided on what the existing baseline of primary school Construction (ID1362) capacity in the designated area, using Bracknell’s School Places

Plan Document 2018 and Government’s school database as basis (excluding independent schools). Consider Warfield (Woodhurst), Warfield (All Saints) and Whitegrove are in designated area which Hayley Green would join; Sandy Lane and Winkfield St Mary’s considered since just outside designated area. Table provided of current capacity:

Capacity Pupils Places Warfield 420 No information No information (Woodhurst) Warfield (All 322 362 -40 Saints) Whitegrove 420 417 +3 Winkfield St 210 202 +8 Mary’s Sandy Lane 630 596 +34 Total (excl. 1582 1577 +5

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I I




Woodhurst)

State an FOI is with Council for detailed school level data and details of proposed school openings/ closures.

Provide information on impact of proposed development at Hayley Green. Used BFC’s methodology (from School Place Plan 2018) and own population yield calculator for comparison:

SHMA compliant mix for 235 dwellings: 1 bed 2 bed 3 bed 4 bed Total

No of dwellings

35 71 82 47 235

Primary age children (4-10 yrs)

1.75 16.33 34.44 18.8 71.32

Using own population yield calculator using very detailed local level 2011 census statistics:

Specific Age Groups Population Pre-school (0-3 yrs) 31 Primary School (4-10 yrs) 48 Secondary School (11-15 yrs) 36 Further Education (16-17 yrs) 14 Working Age Population (16-64 yrs) 369

Consider not enough justification for a new primary school from Hayley Green site alone to fill either a 1FE (210 pupils) or 2FE (420 pupils). IDP not considered to provide any further justification or evidence for the need for a new school on this site. Although not explicitly stated, possible BFC are anticipating other sites will be developed in the area that will lead to a cumulative impact.

Development at Warfield through policies CS5 and SA9 provides 2,200 homes and two new primary school; some phases of development complete/ under construction, remainder do not have planning permission. Allocation intended to be self-contained in terms of primary schools; anticipated will be 2FE and accommodate 420 pupils each. SHMA compliant housing mix would result in:

1 bed 2 bed 3 bed 4 bed Total No. of dwellings

328 665 768 440 2,200

Primary age children

16 153 322 176 668

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Considered these two new primary schools will easily accommodate proposed development with extra capacity (approximately 172 places).

Using same methodology for a SHMA compliant mix for each site, considered new BFLP proposed allocations:

1 bed 2 bed 3 bed 4 bed Total WAR9 0 2 5 3 10 WAR10 1 7 14 8 29 Cluster 5 4 35 73 40 152 (Winkfield Row) Hayley 2 16 34 19 71 Green Total no 5 60 126 70 262 of Pupils

State no site individually triggers need for even a 1FE primary school. The Hayley Green site along with WAR9 and WAR10 only yields 110 pupils – well below requirement for 1FE school. All four sites yield requirement for a 1FE, but considered still well below 1.5FE (315 pupils) or 2FE school (420 pupils).

Draft BFLP requires provision of primary schools on both Hayley Green and Winkfield Row. IDP states Hayley Green should provide on-site provision of a 1FE primary school, with space for 2FE in the future. IDP does not specify exact requirement for Winkfield Row, but draft BFLP shows sufficient land will be provided to accommodate 2FE primary school.

Consider given proximity of sites and pupil numbers, logical to provide one new school at 1.5 or 2FE to meet needs of these developments plus some spare capacity, rather than two separate 1FE schools. Separate requirement on both sites is unjustified. Consider size of Winkfield Row, location of primary school to north of Forest Road (to minimise potential impacts on existing properties) and emerging WNP not envisaging on-site primary school provision at Hayley Green, it is logical to provide one new school at Winkfield Row.

LP7 should be amended: The requirement for on-site primary school provision should be removed.

NB. provided an appendix of child yield calculations (using Bracknell Forest methodology) for several proposed sites and Warfield allocation.

Boyer on behalf of Jordan Construction (ID1362)

Consider ‘Concept Masterplan’ in draft WNP and ‘Illustrative Concept Plan’ in BFLP are fundamentally different. Consider will lead to confusion and potential disagreement once planning

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application submitted. Highlights differences between plans, including completing frontage of Forest Road vs. a primary school; WNP seeking interior of site to remain open green space. Consider local community aspirations at risk of not being realised if on-site primary school requirement taken forward, due to land take required (2.2ha). Consider fundamentally undermines neighbourhood plan making process. Based on anticipated yields, also unnecessary and unjustified.

Boyer on behalf of Jordan Notes requirement for on-site Open Space of Public Value is Construction (ID1362) duplicated in second and fifth bullets points of LP7. The wording of

the policy should be amended to remove the duplicated requirements relating to on-site provision of OSPV.

Boyer on behalf of Jordan Consider boundary allocation in LP7 should be reflected on draft Construction (ID1362) Policies Map for Winkfield and Warfield, and not just developable

area. Consider should be around whole proposed allocation to ensure suitable flexibility for the site. To avoid any confusion between the ‘Illustrative Concept Plan’ in the Draft Local Plan and the ‘Concept Masterplan’ for the site in the emerging WNP, Map 7 should either be amended to better reflect the WNP Concept Masterplan or, if the WNP is made prior to the Local Plan being submitted, the policy should simply cross-refer to the WNP itself.

Boyer on behalf of Jordan Propose allocation at Hayley Green offers an opportunity to create a Construction (ID1360) new high quality residential development that makes an important

contribution to local housing need, wider benefits to the local community that cannot be achieved through piecemeal development. New central green open space for amenity, as well as related accessibility and highways infrastructure improvements. Masterplan will be landscape-led, responding to/ informed by existing trees, hedgerows, topography, established character of Hayley Green. Intend to submit single outline planning application for whole site as per the WNP to ensure comprehensive development.

Turley on behalf of Bloor Noted that the final quantum of development is to be subject to Homes Ltd (ID1434) further consideration in the Warfield Neighbourhood Plan. The

ambiguity this creates is such that the proposed Policy LP7 cannot be relied upon to deliver the amount of development envisaged. For example Policy LP7 refers to "at least" 235 dwellings, where as Policy 2 of the Warfield Neighbourhood Plan states "approximately" 235 dwellings should be provided.

The site is in at least five ownerships, therefore is not likely to come forward quickly, which puts delivery at risk.

There is significant local opposition to t he Neighbourhood Plan's proposal to allocate the site, therefore it is far from certain that it will be carried forward to the final version of the Plan.


The site has been promoted for development through the Draft Warfield Neighbourhood Plan. Given the poor score of the site in the SA, it would appear as though the Council’s decision to propose the site may have been influenced by the Neighbourhood Plan

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proposals. There has been strong opposition to the Neighbourhood Plan Hayley Green allocation proposal, therefore it is not guaranteed it will be taken forward in to final version of the Plan. Proposing the site for allocation in the Draft Local Plan effectively pre-determines the outcome of the democratic neighbourhood plan process. Until such times as the Neighbourhood Plan has been made, the Council should be considering alternative allocation sites to meet its housing need.

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Responses to Section: 6.7. Other forms of residential accommodation.





Binfield Parish Council (ID260) Para 6.52. Suitable accommodation is required with adequate parking (additional visitor spaces), easy access to local facilities and public transport and not hidden at the back of the development. Have an affluent ageing population and to make their larger homes available for younger families there must be attractive options to enable downsizing.

Binfield Parish Council (ID260) Para 6.57. Support policy, and the diversity in housing that it will bring. Wish to see measures to ensure plots are made available to self-builders at a reasonable price. Possibly with a public auction, in which no bidder may buy more than 1 plot, or an auction for those registered (ref 6.58).

Binfield Parish Council (ID260) Para 6.59 – 6.62. Provision of sites would be unpopular for locals and would not reduce the incidence of travellers ‘popping’ up on other sites, with the resulting high costs to move them on and often to clear the debris left behind. Stronger enforcement should also be used to discourage antisocial behaviour.

Does not believe, under current developer proposals, that there is any need for additional traveller sites.

Warfield Parish Council (ID675) Supportive of additional accommodation for older people and care homes. Siting of these considered important in creating a welcoming atmosphere with good access to healthcare and other local facilities. Sufficient parking required, especially for staff and visitors.


Recognition of the need for accommodation for older people is welcomed, but there is a need to ensure appropriate parking is provided. Difference between use classes for retirement living and sheltered accommodation is used by developers to reduce the parking requirement.


There is a need to ensure that integrated retirement and care homes also include fitness facilities, local GP/health facilities or community pharmacy, which should not be impeded by policies which direct such uses towards town centre locations.


Supports the inclusion of self-build.


The GTAA calculations are noted.


None received.


Broadmoor Hospital (ID242) Para 6.56. Policy SA4 of the Site Allocations Local Plan includes provision of a care home / nursing home. Commitment to bringing this forward with the final number of bed spaces to be determined

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through a planning application with the potential to increase the provision.

Bewley Homes Ltd (ID1321) House Builders Federation (ID1278)

Notes the Plan outlines there will be an increase in people living in the Borough. Whilst recognise the needs will fall within the overall housing target, recommend a clear indication of these needs are set out in the plan. Retirement homes form a key part of housing need, which should be specifically recognised / supported.

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Responses to Section: 7. Economic Development/Policy LP8 (sites allocated for economic development)

Responses to Section: 7. Economic Development/Policy LP8 (sites allocated foreconomic development)




Chiltern District Council and South Bucks District Council (ID155)

Comments relate to duty-to-cooperate and soundness of evidence base – emphasise willingness to discuss the issues raised.

Consider that the duty to co-operate documentation accompanying the Draft Plan fails to meet the requirements of the Localism Act 2011, for the following reasons, with respect to South Bucks and Chiltern District Councils (SB&C):

• BFC’s Duty to co-operate Framework fails to record the fact that South Cucks has never agreed the functional economic market area (FEMA) geography defined for the six Berkshire authorities and the Thames Valley Berkshire LEP.

• There are inconsistences between the housing and economic market geographies evidence (latter prepared by NLP, 2016), which concludes there are three functional economic areas across Berkshire (compared to two housing market areas), which supports the case for a single Berkshire-wide functional economic market area.

Binfield Parish Council (ID261) Para 7.4. Figures clearly show the need for more light-industrial, retail and distribution floor space. The fact that more land is not being put forward for economic use does not demonstrate a lack of need, just that the perceived rewards from developing housing is greater than that for employment space (para 7.6). Inflated house prices are leading to the irreversible loss of retail space, pub car parks etc. around the borough.

The council and planners need to get involved as the population is due to increase greatly during the plan period, and these people will need a place to work, eat, shop, have cars serviced etc.

Binfield Parish Council (ID261) During the SHELLA consultation, there was a recurring call from residents for more development of brownfield sites. The recently regenerated town centre has given a taste of what Bracknell has potential to become. Strongly support further regeneration, with an emphasis on mix use schemes, with residential development above and between the employment and commercial developments.


Majority of working residents outside of Bracknell Town commute to work outside the Borough. There has been a lack of control on developers converting business premises into flats and apartments. More provision should be made for allocation of business space in the towns and villages.


WBC supports the principle of additional employment floorspace within Bracknell Town Centre and the protection and intensification of designated Employment Areas. As the proposed allocations would yield significantly less floorspace than required by the EDNA, Labour Supply scenario clarification is sought as to how the intended approach would plug this gap.

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The Western Berkshire Retail and Commercial Leisure Assessment sets out future need for comparison and convenience goods floorspace in Bracknell Forest. Whilst BFC is not intending to meet the identified need in full, the approach is considered to be pragmatic given the recent nature of the town centre redevelopment. Continued collaboration is required on the issue of retail provision.


The Western Berkshire Retail and Commercial Leisure Assessment sets out future need for comparison and convenience goods floorspace in Bracknell Forest. Whilst BFC is not intending to meet the identified need in full, the approach is considered to be pragmatic given the recent nature of the town centre redevelopment. Continued collaboration is required on the issue of retail provision.

Royal Borough of Windsor and Maidenhead

(ID1375)

Further work needs to be undertaken to monitor demand and supply trends of employment floorspace and land so Bracknell Forest can support economic growth and meet the employment needs of the Central Berkshire EDNA, in the light of historic losses of floorspace.

Warfield Parish Council (ID676) Supportive of policy. Bracknell Town Council (ID435) Para. 7.12 / Policy LP8. There is a long standing youth facilities

covenant on the Coopers Hill site which should be taken into consideration. There is a need to ensure continued provision of a community hall / meeting place in central Bracknell, given good links to public transport.


Query why only reference to B1, B2 and B8.

One growth market is health and care industry. Care homes are employment sites in D1 use. The Policy should be expanded to include other uses.


Wallen (ID827) Para. 7.2. Bracknell is part of central Berkshire, not west Berkshire as in para. 6.2

Para. 7.4: typo ‘and’ Jennings (ID1174, 1176) Bracknell is already full. Economic development should be

prioritised where it is needed most; outside the South East. More jobs will simply put more unsustainable pressure on housing.

Hobbs (ID1096) What account has been taken of economic development elsewhere such as Reading or towards London Heathrow.

Gunn (ID1161), Fazey-Gunn (ID1240), Bracknell Friends of the Earth (ID1355)

Table 3 can’t be correct and is out of date as it shows under 10% vacancy rate for office space. There are many offices in the town centre and surrounding areas which are empty, and have been for years. These should be used as a priority for residential rather than using green spaces. These buildings tend to have acceptable existing infrastructure, and easy access to the town centre and local amenities.

Murphy (ID1315) No comment.

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Hewlett Packard Enterprise (ID1330)

Quantum of additional office floorspace identified in the EDNA over the plan period has not been fully considered or reflected on with changing working patterns, efficiencies and the drive to reduce operational space that is currently occurring. CBRE’s market view is that there is no realistic prospect of new office stock being built at the HPE site, particularly given existing evidence of schemes being located in more attractive locations closer to the town centre.

Wyevale Garden Centres (ID754)

Point out that para 21 of the NPPF requires a clear economic vision and strategy for the area which proactively encourages sustainable growth and is flexible enough to accommodate needs not anticipated in the plan. Consider that the plan should make provision for employment sites, located outside of Bracknell – not just mixed-use schemes in Bracknell Town Centre.

Alfred Homes (ID1445) Para. 7.2 indicates that the Economic Development Needs Assessment (EDNA) identifies a requirement for additional Class B floor space. The Plan notes the loss of B1, B2 and B8 floor space and the fact that relatively few sites have been promoted for Class B employment purposes but does not seek to meet the projected employment need.

Persimmon Homes North The Policy does not take account of existing sites which are London (ID1402) allocated for economic development which have not yet been

developed. This includes SALP Policy SA8 (Amen Corner South). Policy LP8 should therefore make allowance of the inclusion of land at Amen Corner South.

Turley on behalf of Bloor The Draft Plan, at paragraphs 7.2 indicates that the Economic Homes Ltd (ID1428), Knight Needs Assessment (EDNA) identifies a requirement for additional and Alfred Homes (ID1443) Class B floor space. However, the Draft Plan fails to respond to this

and does not seek to meet the projected employment needs arsing within the Borough.


Concerns regarding the policy and quantum of employments pace proposed.

The Draft Policy identifies only 6 employment sites for allocation, totalling 34,100 sqm of employment floorspace for B Class uses. This quantum is in contrast with the employment floorspace need identified within the Council’s Economic Development Needs Assessment (EDNA) which found a total need (up to 2036) of 348,520 sqm. The EDNA has not been updated to reflect the new Plan period to 2034, nevertheless, this need figure is overwhelmingly in excess of the proposed allocation of 34,110 sqm.

Syngenta’s Science and Innovation Park plans for Jealott’s Hill would represent a net increase in excess of 70,000 sqm, double that currently proposed for allocation within the Draft Local Plan and a significant stride towards proactively trying to meet the need established within the Council’s EDNA.

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Responses to Section: 8. Strategic Infrastructure (including transport) / Policy LP9 (strategic and local infrastructure)





Surrey Heath (ID110) The A322 forms part of the Government’s proposed Strategic Road Network. The route passes through both Bracknell Forest and Surrey Heath Borough. Surrey Heath Borough Council would welcome the opportunity to work with Bracknell Forest, with regard to any potential future improvements to this route.

Binfield Parish Council (ID262) Many facilities in the borough, and much of the road network, appear to be running at capacity. There are obviously difficulties in widening existing highways, especially where property is very close to the carriageway, such as on Forest Road in Binfield. It is difficult to see how the capacity of the road network can be increased to cope with significant additional traffic, generated from both within and outside of the borough.

Binfield Parish Council (ID262) Road improvements, which are classed as junction improvements, don’t make any contribution to the capacity of the network. Therefore it is important for developments to be planned to reduce the number of car journeys being made. Local shops would allow more people to obtain daily necessities without using the car, or at least without adding to traffic on the major routes, yet there appear to be very few stores. Local schools allow pupils to walk to school.

Binfield Parish Council (ID262) Would expect to see the creation of the new community hub at Blue Mountain. Hopefully the size would be adjusted if proposed development of an additional 74 dwellings at Bin5 & Bin6 goes forward.

Binfield Parish Council (ID262) Wish to support the enhancement and creation of local facilities, and willing to use Binfield Parish Council controlled CIL in conjunction with Borough CIL where necessary.

Binfield Parish Council (ID262) The increasing number of SANGs is welcome, but there would appear to have been no additional sports provision allocated. The local area has extremely strong children’s football participation, but this is starting to be limited by the availability of grass pitches. The existing pitches are over used, and the quality is declining. Need more new pitches, commensurate with the expected increase in population, or have more money spent on maintenance.

Also struggling for capacity for rugby and cricket. (Binfield CC are playing 3rd team home games in Reading, and would like to initiate a 4th team, but cannot find a suitable pitch). Binfield Football Club is currently playing home games at Cantley Park.

With the addition of 1,000 new homes, we do not believe that the pitches will remain available to Binfield residents.

Crowthorne Parish Council Education at all levels should be provided within the individual (ID399) settlements. Where young people are forced to travel to other areas

their friends are from outside of the areas they live and are not therefore part of the community they live in.

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Health Care should be provided within the individual settlement areas.


Public transport needs to be improved. Supports Wokingham Borough Council’s request for more Trains through Crowthorne.

Mayor of London

(Greater London Authority)

(ID1354)

GLA’s demographic modelling provides alternative population and household projections that could be taken into account when applying the standard approach. Welcome the collaborative working in the Western Berkshire Housing Market Area.

Due to good access to M4 and M3 should consider employment needs within the context of the wider area.

Draw attention to Bracknell Forest being located on 2 Draft London Plan Strategic Infrastructure Priority Routes (Policy SD3) North Down Rail Link and Great Western Main Line

Should consider using some of strategic policy transport objectives as set out in Mayor’s Transport Strategy.


Whilst the Plan contains a section entitled ‘Infrastructure’ there is no key diagram showing the required key pieces of infrastructure.

Since the Plan states that more detail on strategic and local infrastructure requirements will be set out in an Infrastructure Delivery Plan (IDP), relevant supplementary planning documents, development briefs and masterplans associated with new major development proposals and allocated sites, it is vital that BFC engage fully with WBC in the production of these documents as a number will have significant impacts on Wokingham Borough. WBC would like to understand at the earliest opportunity what the potential impacts of development would be and what infrastructure is proposed to mitigate this – particularly transport infrastructure –Duty to Cooperate discussions are vital.

Whilst an initial IDP has been produced it is noted that it is to be refined as the plan process progresses. It is essential that BFC involves WBC in the refinement of infrastructure delivery options since many of the impacts of developments proposed will require investment beyond Bracknell Forest in Wokingham Borough.

Royal Borough of Windsor and Welcome the draft IDP to identify key infrastructure (physical, social Maidenhead and green) required. This includes the demand for additional school

places arising from the sites close to RBWM. (ID1373) Royal Borough of Windsor and Maidenhead

(ID1374)

Not clear whether there will be enough SANG capacity for the proposed housing allocations. No information found in draft BFLP and evidence base regarding SANG capacity, number of completed dwellings and financial contributions. The draft Habitats Regulations Assessment (HRA) suggests purchasing SANG capacity for the larger site allocations. Needs to be clearer. Highlight need for further work on air quality.

Royal Borough of Windsor and The 1,282 dwellings proposed in Winkfield would add to pressure on

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Maidenhead transport and infrastructure and have an impact on the local highway network towards the border of RBWM in North Ascot. RBWM note

(ID1373) that further work needs to be carried out to assess the impact of additional travel demand on the safety and capacity of the transport network. Should be undertaken as soon as possible and RBWM should be kept informed of progress and outcomes.

Surrey County Council

(ID1396)

Concerned that there is no reference to cross boundary impacts of proposals for development on Surrey including road network.

The Plan needs to meet the requirements of duty to cooperate, particularly potential cross boundary transport impacts and identification of any necessary measures required to mitigate and appropriately fund the impacts of new development on Surrey’s transport network.

Environment Agency (ID1262) Though generally support the principles and objectives of Policy LP9, particularly in relation to flood risk and waste water infrastructure, recommend some revisions to wording.

In accordance with IDP and the Water Cycle Study (highlighting issues with foul network capacity), recommend policy requires developers provide Foul and Surface water Drainage Strategy at planning application stage at the latest, setting out planned drainage from the site, capacity considerations and evidence of communication with Thames Water regarding network capacity and sewage treatment works to accommodate the flows.

Environment Agency (ID1262) Amend paragraph 8.2 to include Flood Zones, ensuring consistency within the Plan (namely paragraphs 17.2.5 and 17.2.9) where Blue Infrastructure is included within Green Infrastructure definition.

Warfield Parish Council (ID677) Supportive of policy. Thames Water Utilities Limited (ID728)

New development should be co-ordinated with the infrastructure it demands and takes into account existing infrastructure provision.

Reference to national planning policy - local authorities to set out strategic policies delivering water supply and wastewater infrastructure, work with other authorities, consider need for strategic including nationally significant infrastructure, local plans to be the focus for ensuring investment plans of water and sewerage / wastewater companies align with development needs. Adequate water / wastewater infrastructure is needed to support sustainable development.


From 1st April 2018 delivery of water and wastewater infrastructure is changing. All off site water and wastewater network reinforcement works necessary due to new development will be delivered by the relevant statutory undertaker. Will be funded by the Infrastructure Charge (fixed charge for water and wastewater per new property connected). Strategic water and wastewater infrastructure requirements will be funded through investment programmes (based on 5 year cycle Asset Management Plans).

In the above context, support Section 8, Policy LP9 and paragraphs

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8.1 – 8.11. Ensuring necessary capacity exists or new infrastructure in place serving new development is essential. This ensures new development / existing development is not detrimentally impacted.


TWUL are aware of BFC concerns that a number of STW’s will not have capacity for the forthcoming development.

TWUL make clear that Water Companies are responsible for ensuring sewage treatment assets have sufficient capacity. Incoming foul water flows will change according to a number of factors - development in the sewerage catchment; changes in trade discharges; water saving measures uptake, climate change impacts from infiltration.

Assessing Sewage Treatment Works (STW) capacity is complex -based on flow of foul water it can treat and ability to treat the strength (load) of waste to the required water quality standards. The ‘headroom’ of a STW (expressed as a percentage) is the spare capacity at the STW. All STWs take measurements of the final effluent quality (and at all except smallest works, flow measurements also) daily to ensure discharge complies with effluent permit standards. This data can look at trends, implying a STW is nearing capacity.

Detailed computer model assessments are carried out where appropriate. STWs will be modelled so that theoretical capacity is known. The flow and load arriving is compared with the theoretical capacity and verified. This can look at the STW capacity over time, based on known planned development within the sewerage catchment. This process modelling approach also allows an understanding of where in the treatment process upgrades will be required and when.

Where there is concern over future capacity and headroom, TWUL will build in an investment strategy for STW upgrade. This may require working with BFC to improve understanding of the location / scale in specific drainage catchment areas. In rare cases TWUL may require phasing planning conditions, ensuring development reflects STW timing upgrade.


Within AMP6 (2015 – 2020) a scheme to improve the effluent quality is proposed at both Ascot and Bracknell STW’s. This will include a new sludge holding tank and recirculation pumping station.

In AMP7 (2020 – 2025) a study is on-going to accommodate growth in the catchment. It is considering a twin catchment approach, linking two pumping stations sending flows to either Ascot or Bracknell STWs.


Essential that developers contact TWUL as early as possible due to amount of growth proposed in and around Bracknell and the new charging schedule. Once TWUL have a clearer indication of location, scale and phasing from developers, will make a more

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detailed assessment, ensuring the most appropriate solution is in place prior to development being occupied.

Education & Skills Funding Welcomes reference within the plans vision and objectives to Agency (ESFA) (ID817) support the development of appropriate social and community

infrastructure when needed.

Supports the principle of BFC safeguarding land for the provision of new schools to meet government planning policy objectives (para. 72 of the NPPF). Local Authorities should also seek to safeguard land for any future expansion of new schools where demand indicates this might be necessary.

The Council should have regard to the joint Policy Statement from the Secretary of State for Communities and Local Government and the Secretary of State for Education on ‘Planning for Schools Development’ (2011) which sets out the Government’s commitment to support the development of state-funded schools and their delivery through the planning system.

In light of the above, and the duty to co-operate on strategic priorities, the ESFA encourages close working with local authorities during all stages of planning policy.

Note the Council’s reference in para. 8.5 to engagement with relevant infrastructure providers. The ESFA ask to be added to the list of relevant organisation with BFC engages on the preparation of the Plan.

Welcomes the requirement within LP9 for direct provision or funding of infrastructure by developers and the Council’s approach to prioritising and deferring developer contributions where necessary, in line with the IDP.

In light of this, emerging ESFA proposals for forward finding schools as part of large residential development, may be relevant for example if viability becomes an issue. The ESFA aims to clarify forward funding this year.

Recommends that relevant site allocations policies / supporting text in the next version of the Plan clarifies the requirements for delivery of new schools, including when they should be delivered to support housing growth, the minimum site area required, any preferred site characteristics, and any requirements for safeguarding additional land for future expansion of schools where need and demand indicates this might be necessary. For an example of the latter, see draft policy CC7 in Milton Keynes’s Plan:MK Preferred Option draft from March 2017.


Supports the Council’s approach to ensuring developer contributions address impacts arising from growth, though recommend the SPD is

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updated following the adoption of the Plan to ensure it remains robust for securing contributions.

Also recommend the next version of the Plan includes clarification of ‘in kind’ provision of infrastructure. Whilst the SPD explains this term, the Local Plan should set out this position to ensure proper understanding of ‘in kind’ provision which meets the full costs of providing a new facility required as a direct consequence of development (through s.106) as opposed to ‘in kind’ contribution of land in lieu of CIL.


ii) Where part of the developer contribution is deferred, there should be no possibility for the development to claw back the contribution.


iii) Reference to ‘alternative funding sources’ – these are not specified (what are the alternatives, and who is responsible?)


Any independent viability assessment should be commission by the LPA and not the applicant (with cost to be recovered by planning fees).


States only one new infrastructure improvement or enhancement is required. This could be overridden if a viability assessment indicates it reduces a development’s profitability. Developers can use LP9 to their advantage. Expects conflict with site specific policies eg LP6 – due to ambiguity on which policy would take preference

Local bus services are inadequate and there is no reference to an increase in services. There are regular changes and reductions in local bus services, most recently the proposed changes to Route 702. Promote and enhance the current bus system – not everything is about profit.

Provide cycle ways connecting new developments to existing cycle ways to reduce predictable congestion and pollution, and promote wellbeing.

Forest Road is very dangerous for cyclists. Congestion in rush hour occurs as oncoming traffic makes overtaking almost impossible.

In less busy periods, speeding traffic goes on the other side of the road to overtake, particularly dangerous on bends.

Leisure cycling has increased, particularly at weekends.

Question whether traffic movement data includes the additional houses and future projections.

Local educational provision is inadequate. Any future local developments must provide additional schools and a secondary school in particular.

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Brown (ID132) Would like to see confirmation of the projected traffic data for now. It must be possible to verify the current traffic against the projected growth. (Queries whether Council wants to provide this).

Murphy (ID630) Para. 8.1. This seems aimed at site level but could benefit from more masterplanning for e.g. GI, cycle routes, waste water on an area wide basis.

The IDP indicates that much infrastructure delivery is provision or as yet unplanned e.g. alternative transport infrastructure, community including medical, and community hub in north Bracknell.

Para. 8.3. Query whether masterplanning needed, seems to be on a site not area wide level.

Policy LP9. As worded, potentially provides ‘wriggle room’ for developers to escape obligations to provide the entire infrastructure included in the IDP (some of which is already couched in conditional terms such as possible, etc). With CIL funding heavily obligated to large projects, what funding area likely to be available to the route indicated in the second bullet list.

(also see detailed comments on IDP). Society for the Protection for Ascot (ID809)

There is a need to cooperate with RBWM in the development of their local plan. It is critical for Winkfield that BFC pursue their legal duty in this respect to avoid an infrastructure breakdown in this area.

Collings (ID1089, 1072) Para’s 8.6, 8.7, 8.8 (p64-65). It is concerning that current developers appear able to offer payment for infrastructure in return for a huge reduction in the provision of affordable new dwellings. How will this be prevented in the future?

Jennings (ID1174, 1177) Demand is already too high for finite resource, water and transport in particular. Caseless development isn’t sustainable.

Hobbs (ID1097) Para 8.1. The scale of improvements required to deal with transport issues is not achievable. Where is the policy to mitigate the impact of road improvements for residents when contractors commit to working late and at weekends to reduce inconvenience at road improvements?

Hobbs (ID1097) Para. 8.6. Where is the commitment to ensure that contractors and services are laid together?

Green options should be considered before installing traffic lights and making the area urbanised. The rural nature should be a priority.

Glennerster (ID1156, 1168) Strategies to increase non-car use in the area are reliant on 'potential' developers subsidising. Existing and newly allocated employment locations are distant, not accessible by public transport. Car use will predominate, congestion can only increase and with it air borne pollution.

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Gunn (ID1163), Fazey-Gunn Should not build additional housing and neglect supporting (ID1241) infrastructure (reference to existing problems at Winkfield Row and

surrounding roads such as junctions at A322, which will get worse with additional housing).

Gaw (ID1395) Policy LP9 is a weak policy. Clarity is required regarding the wording which states that only one new policy is required – which can be avoided if a viability assessment can demonstrate that is not affordable.


Impressed with the methodology for analysing / providing for infrastructure needs the Council has developed for the urban areas of Bracknell, in particular Bracknell town. However, consider the analysis of needs for the areas east of Bracknell indicate a lack of co-ordination with RBWM / other stakeholders, and demonstrates issues have not been fully grasped, with affordable solutions are unlikely to be found.

Considerable work will be needed to make local roads adequate for development in the east of the Borough. Notes that the Council has ranked proposed allocations at Hayley Green and Winkfield Row the worst for transport accessibility. Accepts it is not necessary at this stage (and would be counter productive) to go into detail about all road solutions. However, a clear vision is needed apart housing to whether transformation of the area between Bracknell and Ascot is appropriate.


The Infrastructure Delivery Plan indicates sewerage in the location of Winkfield Row / Hayley Green is not fit for purpose. Whilst deflecting the responsibility for improvement to a development is a response which could be understandable, this indicates that the proper planning of sewerage infrastructure has not been strategically considered. Masterplanning is required.


Tingdene Parks Ltd (ID372), Support Policy LP9 which recognises that independent viability Bracknell Land Ltd (ID392, 393) assessment will need to be provided where infrastructure

requirements could render development proposals unviable. Given Bracknell Forest has adopted a Community Infrastructure Levy, suggest the policy be amended to make it clear that it is not possible for the Council or Developers to negotiate over CIL contributions.

Gladman (ID1031) Where there is an impact identified from a proposed development and mitigation is required, it is essential that the cost burden is considered within the evidence base that underpins the Local Plan. It is also important that the use of CIL and s.106 is explained so that there is no undue burden placed on development.

Persimmon Homes North There is no allowance within the Policy for mitigation in instances London (ID1403) where the first phase of development is required to provide

infrastructure to support future phases on development. This will result in overprovision of infrastructure and place significant financial burden on developers, resulting in unviable developments.

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Responses to Chapter 9: Introduction

Responses to Chapter 9: Introduction




Binfield Parish Council (ID263) Agree that “Piecemeal development leads to piecemeal road improvements / changes.” Where development occurs in close proximity, (such as along Murrell Hill Lane, Foxley Lane, Amen Corner North) the cumulative impact of development must be taken into account when assessing road infrastructure and services such as broadband, health, education, leisure etc. It is vital that we have adequate roads, community centres, sports facilities, health centres, recreational space etc.

We see many proposals for single form entry schools which need more resources overall than two-form or more schools, and are, not economic.

It is important that when times of austerity and growth coincide it does not lead to inadequate provision. Must plan for the long term, not the short.


No comment.

Warfield Parish Council (ID678) Agrees with policies proposed to be used to assess planning applications; trusts these will be applied equally and robustly.

Bracknell Town Council (ID436) No specific reference to green spaces in Bracknell. Sandhurst Town Council (ID1115)

Para. 9.1.1. Typo should read ‘apply’ not ‘applt.


Para. 9.1.2. What happens if a proposed does not accord with policies is not mentioned. The fact that the LPA can apply conditions/legal undertakings is not referenced.


Para. 9.1.3. The last two bullet points need an explanatory statement, as provided in the other bullets.


Wallen (ID828) Section should be called ‘Development Management Policy’ not issues.

Wallen (ID828) Rumsey/Meader (ID1453)

Para. 9.1.1 – typo ‘apply’.



Bewley Homes (ID 1478) Typo at 9.1.1 - should read ‘apply’ not ‘applt.

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Responses to Chapter 10: Sustainable Development - General





Historic England (ID776) Paragraph 10.1.3: HE wishes to work proactively and positively with the Council to negotiate and bring forward high quality development proposals.

Paragraph 10.1.5: Misinterpretation of paragraph 14 of the NPPF. Presumption in favour of sustainable development still applies to designated heritage assets (only where development requiring appropriate assessment under the Birds or Habitats Directives is being considered, planned or determined is the presumption specifically disapplied). Where designated assets (or SSSIs or Green Belt) are affected, the presumption in favour of sustainable development is applied by paragraph 14 in a different way for plan-making and decision-taking.


Wallen (ID829) 10.1.3. Typo ‘pursuing’.

10.1.4. Words without spaces.

Wallen (ID829), Warfield Environmental Group (ID1193)

10.1.5. Would the Biodiversity Action Plan have a role here too, i.e. if things conflict with its aims.

Jennings (ID1174, 1178) Sustainable is a very subjective word. Very few developments improve the economic, social AND environmental conditions in an area. Greenfield development most certainly doesn't improve environmental conditions and LP10 should reflect this.




The approach set out policy LP10 is largely supported. However, it is considered to be unnecessary to include the term ‘Where appropriate’ at the start of the second sentence of the policy, which reads ‘Where appropriate, the Council will work proactively with applicants jointly to seek solutions which mean that proposals can be approved wherever possible, and to secure development that improves the economic, social and environmental conditions in the area’.

Retention of the term ‘where appropriate’ implies that the Council can pick and choose when to work proactively with Applicants, whereas this should be a starting point for all applications. Removal of the term will not mean that the Council are subsequently bound to support a scheme that is inappropriate for any reason, but will help

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clarify the approach that should be taken.

Proposed Change Remove ‘Where appropriate,’ from the start of the second sentence of Policy LP10.

Pegasus for Rumsey (ID 1454) The approach of Policy LP10 is largely supported. However, it is considered to be unnecessary to include the term ‘Where appropriate’ at the start of the second sentence of the policy. This term implies that the Council can pick and choose when to work proactively with Applicants, when this should be a starting point for all applications. Removal of the term will not mean that the Council are subsequently bound to support a scheme that is inappropriate for any reason, but will help clarify the approach that should be taken.

Bewley Homes (ID 1479) The approach of Policy LP10 is largely supported. However, it is considered to be unnecessary to include the term ‘Where appropriate’ at the start of the second sentence of the policy. This term implies that the Council can pick and choose when to work proactively with Applicants, when this should be a starting point for all applications. Removal of the term will not mean that the Council is subsequently bound to support a scheme that is inappropriate for any reason, but will help clarify the approach that should be taken.


Support the Policy.

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Responses to Policy LP10 (Presumption in favour of sustainable development)

Responses to Policy LP10 (Presumption in favour of sustainable development)




Binfield Parish Council (ID264) Para 10.1.1. Acknowledge that the reasons for the presumption in favour of development in the NPPF are varied, and extend far beyond the scope of the local plan and our response.

Binfield Parish Council (ID264) Para 10.1.2. Supports plan-led development. Planning by appeal is no planning at all. Does not mean that we support uncontrolled and unplanned development just to satisfy the financial aspirations of landowners and developers. Strongly support the creation of a robust Local Plan that will provide a framework and environment within which appropriate development can proceed, to the benefit of both existing and future residents.


There should be a section on settlement boundaries and settlement Gaps.

Warfield Parish Council (ID679) Generally supportive of policy, but remain concerned that BFC keeps policies up-to-date and under regular review.


“where there are no policies relevant to an application” should be clarified. The local plan is a ‘comprehensive local plan’, meaning there should be no applications for which the LPA does not have a policy (out of date or otherwise). Reliance on the NPPF is not a sound plan B.


None received.


Gladman (ID1030) Support the intention of the policy, but this should be reflected across the policies of the plan as a whole.

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Responses to Chapter 11: Development Affecting the Countryside and Green Belt - General

Responses to Chapter 11: Development Affecting the Countryside and Green Belt -General




Warfield Parish Council (ID680) Generally welcome section. Para. 11.1.1 – consider ‘Agricultural’ buildings permitted development rights need careful scrutiny; in semi-urban environment consider they appear to be exploited beyond original intention.


Murphy (ID788) Current defined settlement boundaries more or less results in the opportunity to eliminate remainder of traditional fields and hedgerows with trees that exist within villages. These traditions features considered critical for connecting important areas of countryside and associated biodiversity the Council seeks to protect.

Murphy (ID788) Borough has a mosaic of countryside sites within and outside settlement areas; these need to remain connected. Most species have fluid ranges and cannot survive as isolated populations. Includes all species in all major taxa.

Hobbs (ID1098) Para. 11.1.1. Not sustainable to continue development outside of the Green Belt. Results in overdevelopment, and change of character from rural to urban

Existing settlements such as Hayley Green not being protected.


None received.

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Responses to Policy LP11 (Protection of Countryside)





Binfield Parish Council (ID265) Strongly agree that the countryside must be protected. Binfield Parish Council (ID265) Support limited organic growth of modest, affordable homes only, in

rural hamlets. Binfield Parish Council (ID265) On the matter of extensions, agree that permitted development of

older buildings must only be in relation to the size in 1948. There are too many rural dwellings having extensions upon extensions upon extensions, and this only serves to reduce the housing available and affordable for younger families.


Should be a section to include access and protection of Scheduled Monuments in these areas.

Environment Agency (ID1263) Policy LP11 does not meet Objective B which aims to protect and enhance existing assets including the water environment. Policy should be amended ensuring development will only be supported where river corridors will be protected and enhanced to provide Green and Blue infrastructure, according with Policy LP1.

Warfield Parish Council (ID680) Supportive of policy. Ministry of Defence (Defence (Infrastructure Organisation, Environment & Planning) (ID767)

Consider that the Policy requires further clarification as currently worded there is scope for conflict between Policy LP11 and Policy SA10. Policy SA10 acknowledges the special case for certain development to be permitted without the need to justify development within the countryside. Without clarification, MoD considers that Policy LP11 could create a requirement for the MoD to justify any development in the countryside, undermining the purpose of Policy SA10. Therefore request an amendment to Policy LP11 to include:

ix. is development in accordance with Policy SA10 of the Site Allocations Local Plan.


Policy supported.


Para. 11.1.6. Should be amended to say: The creation of new residential curtilages around any converted buildings can adversely affect the undeveloped, rural character of the countryside, having an urbanising effect and will be resisted.



LP11 vii) supports development of previously developed land, with para 11.1.8 including reference to land identified in the Brownfield Register. Part 1 of the Register has been published, and is a broad brush which may include land not suitable for housing. Part 2 will be land which has had a more thorough assessment. Therefore suggest amendment to supporting text at para. 11.1.8 to read ‘Previously development land includes land identified in the Brownfield land register Part 2.

Murphy (ID631) Para. 11.1.2. phrase ‘committed to protecting the character of the

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countryside….for present and future generations’ contrary to redrawing of settlement boundaries. Countryside seems to be countryside until a boundary is moved.


What is meant by countryside?


First sentence should read ‘…intrinsic character, beauty and environmental value’.

Richardson (ID855) The 8 categories listed are too narrow. There is a need for a policy that allows appropriate extensions to suitable settlement and other well located land for housing, so that a continuous supply of housing land can be achieved to meet the 5 year housing land supply.

Richardson (ID855) No rural housing exception policy contained in the plan. Collings (ID1089, 1073), Warfield Environment Group (ID1194)

vi) Whilst the benefit to humans of outdoor space is well-documented, it should be balanced with the needs of wildlife. In Warfield, the aptly-named Larks Hill has lost its skylarks (UK conservation status red – the highest conservation status, with the species needing urgent action) and it looks likely that the same will happen on Cabbage Hill.

In the development of SANG, why does all of the land have to be accessible to humans (and particularly their dogs which are the greatest risk to wildlife)? Cannot at least some of it be kept truly wild and inaccessible?

Collings (ID1089) Para 11.1.2. Settlement boundaries are never strong and defensible; they are moved either when it suits BFC to do so, or when BFC is forced to do so due to lack of 5-year land supply (Warfield Street).


Leigh (ID73) The draft policy imposes restrictions on types of development outside settlement boundaries and not within specific policy designations such as Green Belt, SPA, SSSI etc – there is no policy basis for this approach in the NPPF (which does not contain any blanket approach to protect the countryside…for its own sake from inappropriate development). Use of the term ‘inappropriate development’ indicates the Council is seeking to impose a control over development in the countryside, which should not exist, it is a term used to control development in the Green Belt.

Reference to the NPPF para 109 which refers to protecting and enhancing valued landscapes, Draft Policy LP11 does not do this, and treats all the land outside of the settlement the same, with no distinction of valued landscape. This is undertaken in draft Policy LP12, so there is no need for Policy LP11 unjustified blanket approach. Also ref to para. 113, and criteria based polices. LP11 is a closed list, not criteria based.

Not disputed that the Council may wish to have a policy that should apply to some type of development outside the settlement boundary,

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and to provide control on some landscape areas of the Borough, but a blanket provision, which seeks to restrict the actual type of development over the whole Borough to essentially that which is allowed in the Green Belt, is not consistent with Government policy (reference to various appeal decisions made).

BFBLP (2002) Policy EN8 is a permissive policy which allows development provided certain criteria are satisfied, so some consistence with NPPF approach.

Policy LP11 should be deleted as other draft Policies in the plan provide control over certain development types (such as LP12, LP15, LP16, LP36), with LP12 providing guidance on landscape and LP11 providing design requirements.

Boyer Planning for JPP Land/Hodge Developments (ID802)

Recognise the importance of protecting areas of countryside for their intrinsic character and beauty, welcome the flexibility provided in draft Policy LP11.

Support (vii) which supports the redevelopment of previously developed sites in the countryside. However, consider to align with the NPPF, the assessment should be based on harm rather than impact, and the following revision is suggested:

“is the redevelopment of previously developed land which would not have any greater adverse impact on result in significant harm to the rural character and integrity of the countryside than the existing development; …”

Pegasus for Rumsey (ID1455) Recognise that countryside designation constrains development, but criteria at Policy LP11 for types of development supported does not allow for new dwellings of exceptional quality, as encouraged in the NPPF (para 55) and Draft Revised NPPF (para 81).

Proposed Change Add criterion ix) comprises residential design of exceptional quality, in that it is truly outstanding or innovative and would significantly enhance its immediate setting, and be sensitive to the defining characteristics of the local area.

Bewley Homes (ID 1481) Recognise that countryside designation constrains development, but criteria at Policy LP11 for types of development supported does not allow for new dwellings of exceptional quality, as encouraged in the NPPF (para 55) and Draft Revised NPPF (para 81).

Proposed Change Add criterion ix) comprises residential design of exceptional quality, in that it is truly outstanding or innovative and would significantly enhance its immediate setting, and be sensitive to the defining characteristics of the local area.

Gladman (ID1029) The policy refers to ‘protection areas of countryside for their intrinsic character and beauty’, which is inconsistent with the NPPF, which refers to recognising the intrinsic character and beauty of the

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countryside.

Reference to court case (Telford and Wrekin v Secretary of State and Gladman Developments [2016] EWHC 3073 (Admin)) which states para. 47 of the NPPF does not include a blanket protection of the countryside for its own sake as existing in earlier national guidance such as Planning Policy Guidance 7.

The policy should therefore be framed that the impact upon rural areas can be considered in the planning balance exercise, as the policy as drafted is considered to be overly rigid.

There are no criteria to support economic development within areas defined as countryside. Policy LP28 takes a pro-active approach to employment development outside of employment areas, which is not reflected in Policy LP11.

As there is a need to maintain a supply of housing against needs identified in a Local Plan, it is considered necessary for any countryside policies to consider circumstances in which a 5 year housing land supply cannot be demonstrated.

Woolf Bond for Warfield Park (ID1286)

(Also see comments on omission sites and Appendix 2).

Object to the policy as this policy as it prevents development on additional park homes within and adjoining the Warfield Park site, which is not consistent with the current approach, saved Policy EN11.

Advocate the inclusion of the park homes site within the settlement boundary of Warfield. This should also include the extent permission for 82 dwellings. Designation of the park within the settlement would comply with the overarching aims of the NPPF such as ensuring the right homes are provided in the places (NPPF paras. 50, 56, 57).

Consider the site provides a natural extension to the settlement, as it is connected and has a direct relationship with the existing settlement. It would also retain a ‘gap’ to Winkfield Row to the north east, which is secured by approved SANG. Existing woodland would also serve as a natural barrier to the new settlement edge.

Reference also made to the Submission Version of the Warfield Neighbourhood Plan, which includes reference to the southern area of the parish as ‘existing built up area’, and includes Warfield Park (Plan C refers), which demonstrates that the Park represents a natural extension to the settlement.

Reference also made to the existing uses and history which are considered to reinforce the suburban nature of the site. In relation to character, designation of the park inside the settlement boundary

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would not prejudice the existing verdant character. A ‘new’ EN11 in conjunction with the settlement designation would allow flexibility, whilst ensuring that any new development would still retain the special character of the park.

Reference made to other examples within Bracknell Forest which would relate to a consistent treatment of other such sites, i.e. Herschel Grange, which is included in a revised settlement within the Draft Plan.

293

Responses to Policy LP12 (landscape character and strategic gaps)





Binfield Parish Council (ID266) Strongly agree that a strategic gap must be maintained between settlements, and particularly between Wokingham and Binfield, and strongly support any policy that allows that gap to be maintained.


Para 11.2.12. Note that the settlement gap between Bracknell and Crowthorne has been omitted. This Gap was enforced in the site allocation SALP 2013 by the External Inspector.

Royal Borough of Windsor and Maidenhead

(ID1372)

Concerned that the majority of proposed new development appears to lie between the urban areas of Ascot and Bracknell. This will significantly reduce the gap between Ascot and Bracknell, place more pressure on transport and other infrastructure, the natural environment and the remaining strip of Green Belt and open countryside. Consider this to be a strategic matter requiring closer engagement.

Note intention to meet housing needs but concerned about loss of gap between Ascot and Bracknell.

Historic England (ID777) Policy LP12: Would like to see criterion ii also refer to the East Berkshire Historic Landscape Character Assessment.

Environment Agency (ID1264) Policy LP12 should also reflect need to protect river corridors to meet Objective B.

Warfield Parish Council (ID680) Supportive of policy. Sandhurst Town Council (ID1118)

Policy not supported.

Wording implies development may be acceptable when in fact any form of development within a gap destroys or erodes its stated purpose/function.

Suggested policy rewording: This statement should read: “Within strategic gaps development will be resisted.”

1st para insert the words “or boundary” to read “including the setting or boundary of settlements.”

“Within strategic gaps development will not be allowed to help retain the separate identity, character and/or landscape setting of settlements and distinct parts of settlements.”


Strategic gaps should be shown on all policy and constraints maps.


The Landscape Character Assessment for Sandhurst needs updating. There have been a number of recent applications approved where the design and built form are out of character. This should not be allowed to continue, or the value of the local character areas assessment or future neighbourhood plan will be undermined.

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Holley (ID311), Barrett (ID322), Crowthorne Village Action Group (ID560), Doran (ID602), Murphy (ID631)

Object to the omission of the strategic gap between Crowthorne and Bracknell in the list of strategic gap (cross reference made to para. 120 of the Core Strategy). Not acceptable to drop a gap because a decision has made to build in the gap. This gap should be reinstated within the Policy/ Crowthorne should remain a separate settlement and not be merged into Bracknell. Suggestion that removal of gap being slipped under the radar by being on page 76 of 287 document. (Some reps also refer to the Site Allocations Local Plan Inspector and importance placed on the strategic gap, Table 4.3 of the “Bracknell Forest Landscape Evidence Base Recommendations”, September 2015 which recognises the strategic gap between Crowthorne and Bracknell, and the “Comprehensive Local Plan Issues and Options”, June 2016, which includes the gap between Crowthorne and Bracknell, para. 9.1.2).

Loss of strategic gap also plays an essential role in protecting wildlife.

(Also see comments relating to loss of gap, summarised in Policy LP4 – land at the Hideout and Beaufort Park).

Rogers (ID360, 363, 365) Crowthorne/Bracknell and Binfield/Bracknell gas have been omitted from the list of strategic gaps. Is this is not an omission, there is a clear conflict with draft Local Plan Objective B, G and 11.2.1 in relation to enhancing setting of settlements and coalescence of settlements. Why has the gap been dropped. Evidence not summarised in the Plan, and not presented at public exhibitions.

Doran (ID602) Loss of strategic gap (Crowthorne/Bracknell) also plays an essential role in protecting wildlife (ref to draft Plan policy LP36 and paras. 17.1.7, page 146 and 11.2.9, page 76).

Collings (ID1089, 1074) Para 11.2.12 Does not understand why strategic gaps, or even local gaps, have not been identified between Binfield and Warfield, and Warfield and Winkfield. It appears BFC’s intention for these (former) villages is to become suburbs of Bracknell.

Hobbs (ID1098) Policy not achievable with developments proposed. Difficult for individual settlements to retain their character. Not clear where the gaps are.

Campaign to Protect Rural Shares local concern regarding elimination of the gap between England Berkshire Branch Crowthorne and Bracknell – which needs to be fully explained (ID1105) (Cluster 3 now proposed to be allocated in the previously defined

gap). Also see comments in relation to (loss of) gaps in relation to proposed allocation sites. In particular LP4, LP5, LP6 and LP7


Wellington College (ID722) Strategic gaps should not be regarded as an absolute constraint -development proposals should be assessed on a case-by-case

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basis in terms of when the location/quantum of development will have a tangible impact on its purpose.

Woolf Bond on behalf of Policy LP12 should be deleted. There is no justification to provide Hodson Developments (ID916- additional protection to gaps when proposed policy LP1 indicates 922), JPP Land and Neal that development will be permitted where it creates high quality built (ID891), JPP Land (ID908), environment alongside enhancing and maintaining local character. Flavia Estates & JPP Land Ltd (ID898), Warfield Park (ID1293) The removal of the previous strategic gap between Crowthorne and

Bracknell associated with the draft allocation LP4 (Hideout/Beaufort Park) confirms this policy will prevent the identification and delivery of key sites.

LP12 is an unnecessary constraint to growth in the borough which is essential to support sustainable development.

We also object to the identification of additional strategic gaps from those listed in policy CS9 of the Core Strategy.

Gladman (ID1028) The Policy refers to “Development Proposals must protect the intrinsic character and quality of the landscape character area within which they are situated”, this is considered to be inconsistent with the provisions of the NPPF.

Noted that the policy supports development proposals for development with settlement gaps where it can be demonstrated it would not adversely affects the gap’s function.

Barton Willmore on behalf of There should be no definition of gaps in the emerging Local Plan. Harrison Housing (ID1062) The NPPF does not restrict or support gaps in principle. Consider

that the function of the land should be based on the approach outlined in Policy LP12 which is criteria based. Whilst object to the designation of strategic gaps, should note that there is no reference within Policy LP12 to other local gaps being designated.

Barton Willmore on behalf of Harrison Housing (ID1062), Willson Developments Ltd (ID946)

Note that para. 11.2.2 states that “all landscapes are valued…”. To state all landscapes are valued is unhelpful as it does not apply a hierarchy to the evident differences in landscape value that exist across the Borough. Although a definition for ‘valued landscape’ as used in the NPPF does not exist, to be considered ‘valued’ a site should have demonstrable physical attributes which take it beyond mere countryside. Therefore consider the word ‘all’ should be removed from para. 11.2.2.

Turley on behalf of Berkeley There are no references to gaps in the NPPF. Para. 109 of the Strategic Land Ltd (ID1471) NPPF states that one way the planning system should contribute to

and enhance the natural and local environment is by protecting and enhancing valued landscapes. Taking account of the different roles and character of different areas is part of a core planning principle underpinning national policy, and therefore Inspectors have found that such policies can be considered consistent, where justified by evidence and specific local circumstances.

The SA acknowledges that the designation of the strategic gap policy may restrict delivery of housing in the Borough. However, the

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consequence of restriction is considered by the Council as being offset by the allocation of sufficient land to meet development needs in the lifetime of the Plan to 2036.

Consider that land at Parkview Farm would be deliverable without resulting in unacceptable coalescence between Bracknell and Wokingham.

Land to the north west of the site is included within the adopted Wokingham Local Plan allocated South Wokingham Strategic Development Location (SDL) site. The adopted South Wokingham SDL SPD (adopted 2011) as comprising a large area of undeveloped open land (outside of the control of the consortium). Beyond this undeveloped land adjoins a proposed sizeable area of new SANG land. Therefore, development of the South Wokingham SDL in accordance with the adopted SPD and development of the land at Parkview Farm will therefore ensure retention of a significant gap between the settlements (as existing and currently committed).


Do not consider there should be a ‘gap’ designation. The NPPF does not support or restrict gaps. Consider the function of land should be based on landscape character assessments rather than a tool to restrict development.

Consider the proposed should be revised to reflect the NPPF: Development proposals must protect and, where possible, enhance the intrinsic character and quality of the landscape character area within which they are situated, including the setting of settlements.


Support the Policy with amendments to criteria i) and iv) as follows:

“Development proposals must protect and wherever possible enhance the intrinsic character and quality of the landscape character area within which they are situated, including the setting of settlements.”

“i. how they protect, and where possible enhance and/or restore the condition, character and features which contribute to Bracknell Forest’s distinctive landscape character; and”

“iv. That they effectively prevent, reduce and mitigate any negative impacts on landscape character.”

Also concerns regard reference to ‘all’ landscape are valued across Bracknell Forest. Therefore consider the word ‘all’ should be removed from para. 11.2.2. (Reference to High Court ruling (Forest of Dean Dc V SoS for Communities and Local Government & Anor).

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Responses to Policy LP13 (rural workers dwellings)

Responses to Policy LP13 (rural workers dwellings)




Binfield Parish Council (ID267) Support the policy as presented for provision of Rural Workers Dwellings, and conditions on their occupancy.


No comment.

Historic England (ID778) Would like a criterion that rural workers’ dwellings be permitted only if there is no adverse impact on the historic environment/heritage assets, or at least a requirement that such development proposals conform with other policies of the Plan.


Policy supported.


None received.


None received.

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Responses to Policy LP14 (occupancy conditions)

Responses to Policy LP14 (occupancy conditions)





No comment.

Warfield Parish Council (ID680) Generally supportive of policy but expect rigorous review of evidence at application stage were a change in occupancy condition requested.


Policy supported.


None received. .


None received.

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Responses to Policy LP15 (equestrian uses)

Responses to Policy LP15 (equestrian uses)




Binfield Parish Council (ID268) Support the policy. Crowthorne Parish Council (ID405)

No comment.

Warfield Parish Council (ID680) Generally supportive of policy. Need to recognise scale and speed of development especially in north of borough, has resulted in many established stables now without appropriate opportunity to hack and exercise. Consider no new stable/equestrian facilities should be permitted in areas where increase in vehicle/cycle/pedestrian activity make horses a danger to themselves and others.


Policy supported.


Jennings (ID1174) Displaced equestrian facilities on Maze Lane could be relocated to WAR10 to help retain character of village Warfield Street.

(Also summarised under WAR10) Wallen (ID831), Warfield Environment Group (ID1195)

Para. 11.4.6. Needs to include something about polo grounds. Removal of hedgerows to create large cultivated fields should be resisted. Use of grass feeds on polo grounds can affect the health of trees within fields. Boundary trees should be pruned appropriately.


Leigh (ID74) on behalf of the Royal Country of Berkshire Polo Club

Criterion i)/para. 11.4.5.: no objection in principle to first trying to re-use existing building, but object to the presumption in the criteria that if it is not possible to then any facility must be integrated with existing buildings, this is an unreasonable limitation on an establishments future plans, not imposed on other rural users. There may be equestrian reasons why this is not possible, for example a proposal to stable horses may have to be kept away from existing buildings on site in the interests of proper equestrian management.

There is no need to prohibit location, criterion i) is not necessary, as other criteria (such as ii-v) set out tests which will be applied to any proposed development (comment made that they are repetitive in their wording).

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Responses to Policy LP16 (Green Belt)





Binfield Parish Council (ID269) Subject to the comments regarding Jealotts Hill, strongly support the protection of the green belt. However, support limited organic growth or rural hamlets in the green belt, but only of modest, affordable homes.


No comment.


Commitment to Green Belt supported. However when comparing previous policies to the current LP16, a number of previous clauses have been omitted. Concerned that LP16 lacks strength and weight of former policies (also cross reference to comments made on Appendix 2).


Bii) Typo delete word “to” from “the proposal must not to result”.


GB review should have allowed development on the edge of existing developments (previously GB Villages). This has adversely affected some of our largest employers by limiting expansion which is beneficial for the community.


Richardson (ID856) No mention of PDL sites in the Green Belt, which is out of step with the NPPF.

Hobbs (ID1098) Maybe some developments in special circumstances should be permitted.


Leigh (ID75) Criterion a) introduces additional test for Green Belt Policy relating to replacement buildings, is not contained in the NPPF (para. 89). Nothing in the NPPF which refers to a new building allowed under para. 89 leasing to an improvement in the openness of the Green Belt. Proposal would be contrary to NPP and case law (specific case referred to Athlone House Ltd v SSCLG, 2015). Para. 11.5.6 refer to the consideration of replacement buildings will not take account of existing outbuildings. Considers this approach to be illogical, as they are buildings and built form which exist so haven impact upon the openness of the Green Belt – no explanation within the para. as to why they will not be taken into account. Approach inconsistent with case law (ref to Tandridge v SSCLG & Syrett, 2015).

Queries purpose of criterion b)/para. 11.5.7. Reuse of building test is set out in the NPPF (para. 90) – which does not make any distinction between any type, age or appearance of building.

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Criterion c) is not consistent with the NPPF – the Council is attempting to reintroduce the concept of ‘Green Belt Villages’, previously contained in the Bracknell Forest Local Plan 2002. Reference to the Council since acknowledging this approach is not consistent in the NPPF, and have not been applying policies relevant to that previous designation. Also reference to approach taken in the RBWM Local Plan submission, and reference to case law. Para. 879 of the NPPF referred to limited infilling in villages will be allowed, there is no provision for setting out ‘identified settlement boundaries.

Cogito Consulting Limited for Bilton Land Ltd (ID237)

The existing defined Green Belt Village of ‘Prince Consort Drive’ should be reinstated the proposed list, and be extended in geographical area.

There is no stated rationale within the Plan for the change in the status of the Prince Consort Drive, which has been established as such since 2002.

The boundary of the existing GB village at Prince Consort Drive should be extended to reflect the pattern of development:

A) The existing character area boundary B) Kings Ride Park (which is a mature established small

business park) C) Kingswood – former business park with permission for

housing redevelopment of 38 units

Jones (ID600) Consider changes are required to make Policy LP16 sound.

Point (a) of the policy requires that replacement buildings ‘demonstrably improve[s] the openness of the Green Belt’.

The NPPF (para 89) sets out that infilling or redevelopment must ‘not have a greater impact on the openness of the Green Belt and the purpose of including land within it than the existing development and that replacement buildings must ‘not [be] materially larger than the one it replaces.’ Point (a) should be amended accordingly: (a)The replacement of a building, provided the new building is sited on or close to the position of the existing building, except where an alternative siting within the curtilage demonstrably improves the openness of the Green Belt has no greater impact on openness than the one it replaces by virtue of size, scale and/or siting.

Pegasus for Rumsey (ID1456) First sentence of Policy LP16 is inconsistent with wording of NPPF (para 89) or draft revised NPPF (para 144) which sets out exceptions where new buildings are not considered inappropriate, as recognised in the second line of Policy LP16. A conflict therefore exists within the policy itself.

Proposed Change

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Re-word the first sentence of Policy LP16 to ensure it is consistent with national policy on such matters.

Bewley Homes (ID 1486) First sentence of Policy LP16 is inconsistent with wording of NPPF (para 89) or draft revised NPPF (para 144) which sets out exceptions where new buildings are not considered inappropriate, as recognised in the second line of Policy LP16. A conflict therefore exists within the policy itself.

Proposed Change

Re-word the first sentence of Policy LP16 to ensure it is consistent with national policy on such matters.

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Responses to Policy LP17 (developed sites in the Green Belt: Syngenta)





Binfield Parish Council (ID270) Strongly support the development of the Syngenta site for research and residential use. Any substantial residential development must include schools, local retail, a pub etc. to form a community. It would need to be a complete community not merely housing. The alternative is increased traffic on roads throughout the northern parishes.

Surprised and concerned that, given the willingness of Syngenta to develop this site and its suitability for providing a very significant number of houses in a most sustainable location, the site is not included in the local plan for development.


No comment.

Warfield Parish Council (ID680) Recognise important role Syngenta plays to employment and economic activity within borough, nationally and internationally.

Warfield Parish Council (ID680) Clarity should be provided on what is envisaged by ‘aims to provide guidance on how the site may be adapted and developed to meet the changing needs of the business’ in line with NPPF paras. 89 and 90. Expect any proposals for complete redevelopment to be considered on own merits rather than permitted through policy LP17. Request this section be removed.

Warfield Parish Council (ID680) Remain opposed to piecemeal/ substantial residential development at the site.

Warfield Parish Council (ID680) Welcome proposal to remove land from the developed site boundary.


Partially support policy. Any proposed development outside the current built envelope (defined where there is current development that could be classed as PDL) must be resisted. There are no very special circumstances to justify the complete redevelopment of the site.


Murphy (ID650) Map 8 in appendix unclear that land to be removed from PDL in the Green Belt is being returned to the Green Belt.

Hobbs (ID1098) Policy only ok if it relieves pressure on the building of housing in other areas identified in the plan, otherwise no.


Pegasus for Rumsey (ID1457) Objective of Policy LP17 is identified as being to protect /enhance existing assets. Such an approach is entirely understandable given the Council’s recognition of their limited stock of employment land across the Borough. Given this objective, it would be appropriate and necessary to confirm within the policy that any redevelopment

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proposals for the site should focus upon employment use.

Proposed Change

Bewley Homes (ID 1480) Add to Policy LP17 criterion iv) be retained in employment use Objective of Policy LP17 is identified as being to protect /enhance existing assets. Such an approach is entirely understandable given the Council’s recognition of their limited stock of employment land across the Borough. Given this objective, it would be appropriate and necessary to confirm within the policy that any redevelopment proposals for the site should focus upon employment use.


Proposed Change Add to Policy LP17 criterion iv) be retained in employment use Consider it likely that there will be plans to redevelop Jealotts Hill Research Centre during the plan period. Opposed to it being used for general housing if redeveloped. Most suited to a site for a retirement village – could help achieve needs set out in SHMA.


Consider that the proposed new Science and Innovation Park at Syngenta, should be included as an allocation within the Draft Plan. If included, then this policy should be removed. If the proposals are not allocated, them comments on Policy LP17 should be reflected, to more closely align with the NPPF policy on Green Belt redevelopment:

“Policy LP17 - Developed Site in the Green Belt: Jealott’s Hill International Research Centre

Development within the built envelope of the Jealott’s Hill Research Centre as defined on the Policies Map and comprising infilling and / or partial or complete redevelopment will be permitted provided that it would:

i.

i i .

i i i .

Not significantly extend beyond the defined built envelope which contains the bulk of the built-up area of the site as defined on the proposals map; and Be visually contained within the site and not significantly exceed the scale or height of the existing buildings; and Not have a greater impact on the openness and undeveloped character of the wider Green Belt or the purpose of including land within it.

Partial or complete redevelopment proposals will be permitted provided that they would:

i. i i .

Not lead to an over intensification of the site; and Result in environmental improvement to the site.”

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Responses to Policy LP18 (Design)

Responses to Chapter 12: Character and Design





Binfield Parish Council (ID271) Well designed, pleasant and welcoming communities are an aspiration for all. However, there is a conflict between adequate provision and the financial aspirations of developers such as parking and bin storage.

Minimum requirement for parking is the goal for developers, particularly in reference to 1 and 2 bedroom houses and visitor parking. There appears to be no use of current parking issues to ensure it is not repeated across new sites. Until there is a change of attitude to the use of cars, this parking problem will continue which is not conducive to a good street scene and we are passing this problem on to future generations.

Suitable bin storage for each property is absolutely necessary to for the various bins. If we do not wish to have the street scene detrimentally affected, bin storage must be afforded the same thought as parking spaces.

Crowthorne Parish Council (ID408) Needs objective for development to be in line with current character and design of existing buildings.

Historic England (ID779) Support for Policy LP18, particularly the reference to iii and v. However, conservation area appraisals should be added to the list of reference documents.

Environment Agency (ID1265) Support Policy LP18 reference to features of ecological value (iii). This should be extended to include the aquatic environment and river corridors and links made to Objective B.

“Where reasonable” should be removed as this significantly detracts from overall policy aims, that all development must have a positive contribution to local character.

Warfield Parish Council (ID681) Consider provision of measures in the design to encourage wildlife should be added to policy. Would like garden boundaries that allow access for wildlife and maintenance of green corridors/ facilities for crossing points for wildlife. Do the space standards include garages and storage provision?

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Warfield Parish Council (ID681) Consider street lighting should be sympathetic with the local area; low-level lighting should be used where appropriate. Consideration should be given as to whether lighting is appropriate.

Sport England (ID1042) Sport England along with Public Health England have launched our revised guidance ‘Active Design’, it would be useful to provide a cross-reference and link) to this document: www.sportengland.org/activedesign Sport England would encourage development in Bracknell to be designed in line with the Active Design principles to secure sustainable design. This could be evidenced by use of the checklist. A suggested model policy for Local Plans and Neighbourhood Plans included.

(ID1121) Sandhurst Town Council Design should reflect a positive approach to climate and buildings should not overheat. Buildings should maximise the use of renewable energy for long term economic factors.

(ID243) Broadmoor Hospital – West London Mental Health Trust (1157990)(1157993)

Support for the objective to achieve high quality development. However, it is stated that Design Codes are not always required to agree a vision or strategy for development for larger and more complex developments and that a range of approaches is possible to achieve good design. More flexibility is requested and alternative wording is suggested within the policy and para 12.1.11 “Masterplans, Design Statements and Design Codes may be required for larger and more complex developments involving multiple parties to achieve a high standard of design that demonstrates a comprehensive and inclusive approach.”


(ID062) Balding Main issue of concern is recycling facilities in new developments, especially in apartment blocks. Recycling enclosures should have roofs. Questioned whether waste shoots in apartments were a good idea? Asked how office to apartment conversions had to comply and whether BFC would be progressing to recycling Food Waste and Textiles.

(ID205, 206, 207) Brett No details relating to the types of houses to be built, design details are not clear and nothing is stated which references the historic beauty of the location of Cluster 5

(ID313) Gierth Would like to see the policy detail measures to

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http://www.sportengland.org/activedesign




encourage wildlife e.g. garden fences to allow passage of wildlife, maintenance of green corridors between SANG e.g. road tunnels etc..

(ID332) Bruen The proposed density for the Winkfield site allocation is in excess of existing densities in Winkfield Row and Hayley Green and is therefore out of character with the area.

Green spaces in Winkfield Row and Hayley Green could seriously be eroded.

(ID352) Fullerton Insufficient evidence is provided to show that the proposals for the site allocations meet the criteria set out in the Overarching Design policy in relation to creating character and respecting local heritage and existing patterns of development

(ID632) Murphy Difficult to see how the Concept Plan and proposals, with twice as many new homes compared to the linear development of existing community, can meet the requirements set out in the Overarching Design policy, LP18, and proposals do not respond to the “important setting of Hayley Green”.

LP18, Design SPD and Character Area Assessments SPD do not provide robust guidance to new development behind or adjacent to small linear settlements. In fact, such proposals would be contrary to policy

Murphy (ID632) Para. 12.1.9. Transport infrastructure indicated here is provisionally indicated in the IDP.

Lyes (ID798) Cluster 5 does not conform to LP18 due to the density proposed and the fact that the levels of housing would not respect the pattern of development in the existing character area in the Northern Villages chapter of the Character Area Assessments SPD. Erosion of the historic character and townscape, existing linear/ribbon development and the open rural gap between Winkfield Row North and South Winkfield.

Collings (ID1089, ID1075 and 1196) Para 12.1.1 (p92) Policy LP18 Design ii) … have regard to solar orientation … Why not go further and specify that some form of solar energy collection be installed on all appropriate new dwellings? It must be easier and cheaper to install during the build rather than retrospectively?

Collings (ID1089) Para 12.1.5 (p93) Developers should carry out tree surveys … Surely it would be better if BFC did this.

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How many times have we seen trees and hedgerows disappear at the weekend when nothing can be done to prevent it?

Jennings (ID1174) Recent developments, including Woodhurst Park, have failed to achieve a high standard of design. For example, hedgerows that provide vital wildlife habitat have been needlessly destroyed. It is hoped that the council will rigorously enforce LP18.

(ID1196) Warfield Environment Group Land at Hayley Green will involve the removal of historic mature hedge if as per concept plan. Therefore does not meet LP18 iii LP18 should go further in terms of solar energy collection on new dwellings BFC should do tree surveys to ensure removal is not in the hands of developers

Rumsey (ID1458) Point iii) insert Retain “as appropriate” as it will often be inappropriate due to the condition and the wider intentions of the scheme.

Maidens Green Society (ID1576) Notes that pressure from the Government, but considers that good design makes for happy communities and Council respect, as people will be living with BFC decisions long after the developers have gone. Request that design key part of decisions. Suggests a design panel who are able to challenge speculative design for the better.


Broadmoor Hospital (ID243) The requirement for Design Codes for larger and more complex developments is not always needed to agree the vision and strategy for a development and the Planning Practice Guidance recognises a range of approaches. Flexibility in the wording is needed with alternative wording: “Masterplans, Design Statements and Design Codes may be required for larger and more complex developments involving multiple parties to achieve a high standard of design that demonstrates a comprehensive and inclusive approach.” Amended wording should be carried forward to para 12.1.11.


Whilst the retention of trees and other features will often be desirable, the wording of criterion (iii) currently indicates all such features should always remain. This will often be inappropriate due to the condition of the feature and wider intentions of proposed scheme.

Proposed Change Amend the wording of criterion (iii) of Policy LP18 to ‘Retain, as appropriate, and, where reasonable,

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enhance existing trees…………’ Bewley Homes PLC (ID1485) Point iii) insert Retain “as appropriate” as it will

often be inappropriate due to the condition and the wider intentions of the scheme.

Wilson Developments Ltd (ID948) Support for the policy and its comprehensiveness Barton Willmore on behalf of Harrison Housing (ID1061) and Willson Developments Ltd (ID948)

Support for Policy LP18 and its comprehensiveness

(ID1381) Boyer on behalf of W Channing and Sons; Boyer on behalf of Jordan Construction (ID1363)

No definition of “larger and more complex developments”. Therefore, where is the threshold for masterplans and design codes? Unclear at what stage of the development management process each document is expected to be submitted; should a masterplan come in with an Outline application? Will a Design Code be secured by condition or be part of a Reserved Matters application? Neighbourhood plans form part of the Development Management process – they are not a Supplementary Planning Document as could currently be implied by the wording of the policy.

Persimmon Homes North London (ID1404) No reference is made to the density of development within the policy, amended wording is suggested as follows “Achieve a density of development which is appropriate to the location and context of the site”

Pegasus for Rumsey (ID1458) While retention of trees / other features is often desirable, wording of criterion (iii) indicates all such features should always remain. This may be inappropriate due to the condition of the feature and wider intentions of the proposal.

Proposed Change

Amend the wording of criterion (iii) of Policy LP18 to ‘Retain, as appropriate, and, where reasonable, enhance existing trees…………’

Pegasus for Rumsey (ID1459) PPG states at para 56-020 that; ‘Where a need for internal space standards is identified, local planning authorities should provide justification for requiring internal space policies. Local Planning Authorities should take account of the following areas; need, viability and timing’

Council has not provided sufficient evidence against the above 3 criteria, and as a result policy is not justified and not in accordance with national guidance.

Barton Willmore for Syngenta (ID1558) Support for the policy, especially innovative, efficient and sustainable solutions to development

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that integrate with the surrounding landscape.

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Responses to Policy LP19 (Tall Buildings)





Binfield Parish Council (ID271) Tall buildings must be confined to the town centre locations, and to a lesser degree, to the industrial areas .Tall buildings in the outer parishes would be completely out of keeping with their more suburban and rural natures.


Policy should be strengthened to be in keeping with surrounding buildings in towns and parishes where tall buildings don’t exist

Historic England (ID780) Concerned about reference to “a point of townscape significance”, as such significance might be historic and/or derive from historic buildings or features on the site, with which the tall building would compete for dominance and harm the significance of the historic building or feature. Principle in paragraph 12.2.16 should be enshrined in the policy itself as another requirement. Query whether studies have been done to ascertain where tall buildings would and would not be acceptable.

Warfield Parish Council (ID682) Expect any tall building proposals to take account of findings of Grenfell Inquiry.

Bracknell Town Council (ID437) Tall buildings are recognised as an appropriate form of development in the Town Centre, but need to bear in mind the needs of occupants, such as open/green space, and adequate refuse clearance arrangements.


Policy supported.


Gierth (ID315) There is no mention of safety. With recent Grenfell fire this might be a useful additional to the policy.

Murphy (ID633) Para. 12.2.4. What criteria can regulate this. Three story development at Newell Green and Woodhurst seem out of character.

Murphy (ID633) Para. 12.2.11b. Include of A330 east of Hawthorn Hill to Malt Hill. Wallen (ID832) Para. 12.2.11b. Include Garth Meadows, Warfield and Frost

Folly/Jealotts Hill area of Warfield. Collings (ID1089)(1076) Para 12.2 (p95-98) welcome this section and hope the policy is

applied rigorously. It may have prevented, or at least modified the design of the apartments near the Spice Lounge (Three-Legged Cross) in Warfield which are inappropriate in their placement.

Collings (ID1089, 1076) Para 12.2 (p96) Policy LP19 Tall Buildings (ix) they include sufficient parking for cars … The policy of one parking space for a one-bedroom flat is unrealistic. Whilst in theory it might encourage a couple who live in such a flat to own just one car, in practice it doesn’t and causes parking difficulties. Please use some common sense.

Collings (ID1089) )(1076) Para 12.2.3 (p96) a definition of ‘substantially taller’ is required. Jennings (ID1174)(ID1180) Excessively tall buildings at Woodhurst Park have had a detrimental

impact on the views in various parts of the surrounding area. Hope

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that this policy is policed effectively in future. (1135) Tom Neill Disappointed that the Winchester House site will contain a building

as un-exemplary as its predecessor.


Persimmon Homes North London (ID1405)

The Policy is overly prescriptive and restricts the development of tall buildings, which does not allow for flexibility/originality of design approaches advocated in the NPPF (paras. 59 & 60). Therefore do not consider the Policy to be justified or consistent with national policy. Also consider the Policy to be inconsistent with the draft Policy LP1 which seeks to make efficient use of land – development proposals which include tall buildings assist in promoting efficient and effective use of land.


Agree with the suggested policy. Support proposals for tall buildings should reflect the character of the area, including relationship with adjoining buildings, and should be of high quality.

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Responses to Policy LP20 (Internal Residential Space Standards)





Binfield Parish Council (ID271) The standard sizes appear to be becoming increasingly smaller in new properties and there is a definite lack of internal storage. Second or third bedrooms in majority of modest homes are little more than box rooms.

Minimum standards appear to be viewed by many developers as a target, and as such must not be allowed to reduce space to the minimum. New development should include good storage facilities both inside and outside a home. One of the reasons why garages are not used for vehicles is because there is inadequate storage provision in homes.


Include reference to parking policy.

Warfield Parish Council (ID683) Unclear if internal space standards include garage and storage provision.

Bracknell Town Council (ID442, 443)

Inclusion of this section welcomed.

Sandhurst Town Council (ID1122).

Policy not supported. Space standards are too small, and will affect the health and wellbeing of future occupants. Built-in storage bears no relationship to actual storage needs. If a 1-bed property as 1sqm, shouldn’t a 4-bed have 4sqm? LPA need to explain what it would accept as a minimum space standard.


Gierth (ID317) Not clear whether the space standards includes or excludes garages.

Collings (ID1077) No comment.


Wellington College (ID723) Need to clarify that the policy relates specifically to new dwellings and does not cover Class C2 residential institutions uses, such as boarding houses (regulated separately).


Made submission at the Issues and Options stage that this policy is removed, continue request. Para. 12.3.7 confirms the policy applies to creation of all new dwellings, yet the NPPG (2014) para. 18 confirms the requirement is optional. Recommend the policy is removed, and not apply to conversion of existing offices to residential. Instead recommend each application should be assessed on a case by case basis.

Woolf Bond on behalf of Hodson Developments (ID916-

Object to this policy. There is no evidence within the viability assessment that constructing homes with these standards would be

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922), JPP Land and Neal viable. Planning Practice Guidance (paragraph 20 – ref ID: 56-020-(ID892), Flavia Estates & JPP 20150327) states that “evidence should be provided on the size and Land Ltd (ID 899), JPP Land type of dwellings currently being built in the area, to ensure the (ID909), Warfield Park (ID1292) impacts of adopting space standards can be properly assessed.” Boyer on behalf of Shanly In terms of need, the PPG is clear that the Council must provide a Homes (ID1346), W J Channing local assessment evidencing the specific case which justifies the & Sons (Woking) Ltd (ID1382) inclusion of nationally described spaced standards in a new Local

Plan. Only evidence is para. 12.3.4, with the associated footnote 18 web link ‘page not found’. Therefore, there appears to be no substantial evidence as to the need for national described space standards.

In terms of viability, para., 12.3.4 states the Policy is being tested, however it is not clear how this has informed the viability assessment.

In terms of timing, the Council will also need to consider any effects on delivery rates.


This policy is not required. Paragraph 12.3.4 refers to a survey of residents who stated that new developments need more storage. This is not “clearly evidenced need”, as required by the Government to justify the inclusion of these space standards in development plan policy.

The policy is an unnecessary regulatory burden on housebuilders and developers, which is not necessary or needed. The council has not justified its inclusion in the plan and policy LP20 should be deleted.

Alfred Homes (ID1440) Policy is not in conformity with national planning policy since Planning Practice Guidance states that such standards should only be applied where there is a justification for such, taking account of housing need, viability and implications for timing. No justification has been provided.

Bellway Homes PLC (ID 1486) Para 56-020 of the PPG makes it clear that justification is required for internal space policies in terms of need, viability and timing’.

The Council has not provided sufficient evidence against the above 3 criteria, and as a result implementation of the policy is not justified or in accordance with national guidance.


If a Council wishes to adopt Nationally Described Space Standards (NDSS), in line with para. 56-020 of the PPG, it should be justified.

Need: A Council should provide a local assessment evidencing a specific case for NDSS, which at present has not ben undertake.

Viability: Whilst the Viability Study mentions space standards, it is not clear how these have informed the viability assessment. A more in depth assessment of impacts is required. Requirements for space standard will reduce yields, less efficient use of land.

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Timing: The Council should take into account adverse effects on delivery rates, and should include proposal for transitional arrangements. Land deals underpinning the majority of sites will have been secured prior to any proposed instruction of the nationally described space standards.

Boyer for Bloor Homes Limited (ID925)

In order to adopt the national described space standards, the requirements of para. 56-020 of the PPG need to be fulfilled, and a local assessment evidence the specific case for Bracknell Forest should be provided. No evidence provided, a link referred to in footnote 18 of the Plan does not work. The “New Developments Residents Survey 2014” is not considered a sufficient evidence base.

In terms of viability, not clear how the standards have informed the viability assessments. The ‘Viability Assessment for the Comprehensive Local Plan Strategic Housing and Economic Land Availability Assessment’ (2017), prepared by BNP Paribas Real Estate, only includes one reference to space standards at para. 1.22.

Policy LP20 will place an additional policy burden which will impact on build costs and viability/sales prices.

Suggested amendment to the Policy as follows:

“Proposals for the creation of new residential units will meet as a minimum, the nationally described space standards, where possible…”

Gladman (ID1027) Requirements should be fully evidenced in line with para. 56.020 of the PPG. Care should be taken to ensure that generic arguments are avoided in eth justification. A local assessment evidencing a specific case is required.

Persimmon Homes North Approach not justified. London (ID1406)

One size fits all approach: implications of imposing standards not been fully assessed – no evidence provided. Should be determined on a case by case basis, not a blanket borough wide basis.

Affordability: by forcing developers to build larger dwelling types, this will increase construction prices and have a knock on effect on hose prices. Introduction of spaces standards will remove the choice to buy a new build property for many potential purchasers. Creation of houses at different sizes allows the creation of different price points.

Need & Viability: the survey of new residents (September 2014) does not demonstrate that the current housing market does not meet current local needs. To the contrary it shows nearly three quarters

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of residents agree their home has sufficient space. The survey was undertaken in 2014, and does not provide an assessment of properties construction since this date, so is out of date.

Efficient use of land: Requirement for internal space standards would reduce site yields or the number of units on a site, therefore amount of land needed will increase. Efficient use of land would be less as development densities would decrease. Infrastructure and regulatory burden on fewer units per site increases the challenge of meeting residual land values which determines whether or not land is released for development by a willing landowner.

Timing: no interim arrangements are proposed, which does not accord with the NPPG. Majority of land deals on identified sites will have been secured prior to the Council’s proposed introduction of nationally described standards. A clear strategy for transitional arrangements in needed within the Policy.

Boyer on behalf of Jordan In order to adopt the national described space standards, the Construction (ID1363) requirements of para. 56-020 of the PPG need to be fulfilled, and a

local assessment evidence the specific case for Bracknell Forest should be provided. No evidence provided, a link referred to in footnote 18 of the Plan does not work. The “New Developments Residents Survey 2014” is not considered a sufficient evidence base.

In terms of viability, not clear how the standards have informed the viability assessments. The ‘Viability Assessment for the Comprehensive Local Plan Strategic Housing and Economic Land Availability Assessment’ (2017), prepared by BNP Paribas Real Estate, only includes one reference to space standards at para. 1.22. Council needs to undertake a more detailed assessment of the specific impacts on introducing the nationally described space standards on the viability of individual development sites.

If taken forward, need to consider adverse effect on delivery rates of sites included in housing trajectory. May necessitate need for transitional arrangements as land deals underpinning the majority of identified sties will have been secured prior to any proposed introduction of nationally described space standards. Should allow sufficient time for such sites to move through planning system before any proposed policy requirements are enforced.

Barton Willmore on behalf of Harrison Housing (ID1060), Willson Developments Ltd (ID949), and Syngenta (ID1559)

Consider the Technical Housing Standards should be a guide to allow for flexibility, on the basis they are not statutory, and will be subject to review (reference made to para. 56-001 of the PPG).

Turley on behalf of Bloor Homes Ltd (ID1430), Knight and Alfred Homes (ID1440)

In accordance with the planning practice guide, standards should only be applied where justified. No such justification has been provided.

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In accordance with the planning practice guide (para. 56-020), standards should only be applied where justified. No such justification has been provided.

The impact of introducing standards upon viability is also required to be justified. The instruction of standards would reduce site yields and affect efficient use of land.

Consideration should also be had to the consideration of adverse effects on the delivery rates included in the trajectory. The policy should also include provision for transitional arrangements.

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Responses to Policy LP21 (Protection of Existing Housing Stock and Land)

Responses to Chapter 13: Housing

Responses to Policy LP21 (Protection of Existing Housing Stock and Land)




Binfield Parish Council (ID273), Warfield Parish Council (ID684)

Support the policy.


Should include buildings that should be included as a heritage asset and be protected.


Policy supported.

A paragraph to explain how bringing back into use long-term empty housing might be achieved would be useful.


Tuffley (ID1010) States comments to make, but no comments made.


None received.

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Responses to Policy LP22 (Housing for Older People)






Although provision has been made for specialist housing sheltered and extra care, no provision made for elderly who do not need extra help, but wish to downsize. Parking provision in extra care housing needs to take account of extra space required for staff. (Reference made to provision at Clement House being inadequate, and should not be repeated.)

Binfield Parish Council (ID274) Specialist communities for older people can lead to isolation. Strongly support the building of properties that are adaptable for older people in the heart of the community. A vibrant community requires a mix of all types of people to make it work.

Binfield Parish Council (ID274) Suitable accommodation is required with adequate parking (additional visitor spaces), easy access to local facilities and public transport and not hidden at the back of the development. We have an affluent ageing population and to make their larger homes available for younger families there must be attractive options to enable the older generation to downsize.


Needs to ensure retirement and nursing homes are not centred in one area.


Policy supported.

Where applications for care homes include proposals in other use classes such as fitness, health, pharmacy, policies which usually direct such uses to settlement/town centre locations should not prevent this type of proposal, as their inclusion has a wider community benefit.


Para. 13.2.3. Policies should be strengthened to ensure adequate parking is provided for facilities (applicants state one use class which has a minimal parking such as sheltered housing, then market as retirement living).


Brett (ID208, 209) Insufficient information provided on housing for older people. Wallen (ID833) Need to include reference to resisting conversion of bungalows into

two storey dwellings, as this reduces the choice of housing. Wallen (ID833) Need to ensure bus routes which enable travel to shops and

surgeries, or have facilities close to point of need. Need a supply of small neighbourhood shopping centres/community centres for day to day needs.

Butcher (ID980) Policy supported, however does not consider enforceable. This policy needs to be proactively pursued, written into Conditions when plans are approved, and ultimately delivered.

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Collings (ID1078) Policy is supported.


Hunter Page Planning for Comments made of behalf of a specialist company working Castleoak (ID54) exclusively within the care sector.

Pleased to see the provision of a specific policy, however the policy appears to take a simplified approach to housing for older people, suggesting a requirement in C2 use simply relates to bed spaces/traditional care homes.

Housing requirements for older people is far more complex and accommodate such as Assisted Living units can ensure couples stay together for longer when one or both are in need of care. There are numerous appeal decisions to demonstrate these are C2 uses.

Hunter Page Planning for The estimate in the SHMA and the Housing Background Paper that Castleoak (ID54) there is only a requirement of 14 bed spaces per year over the plan

period appears a very low estimate given that the population over 65 is due to increase by almost 90% over this period. Research carried out by Castleoak has shown that in 2019 that there will be an undersupply of 245 Assisted Living Units in 2019 increasing to 340 Assisted Living Units in 2026.

Bewley Homes (ID1323) Supportive of the policy since specialist care should be provided for the increasing proportion of the Borough’s population that is over 65. However, the need to be in a sustainable location with access to everyday services would not be a requirement for all types of specialist housing where residents have dementia or mobility problems (as highlighted in the POPPI data). It is unlikely that residents of such care homes would use such facilities and therefore the policy should be re-worded to remove the requirement to be close to shops and in a sustainable location.

Bewley Homes (ID1323) Notes that the list of key evidence is extensive but the following should be added to the Housing Section of the Evidence Base: - Bracknell Forest Joint Health and Wellbeing Strategy 2016 –

2020 - Bracknell Forest Older Persons Accommodation and Support

Strategy 2011 – 2016 - Projecting Older People Population Information System (POPPI)

Bewley Homes (ID1323) The monitoring of the delivery each year will be imperative especially when part of a larger strategic allocation or part of a comprehensive redevelopment. Monitoring of the number of Class C2 and Class C3 specialist homes should include the numbers of specialist accommodation lost, to ensure that the Council are aware of changes to the level of provision across the Borough. Examples of two care homes lost through approved changes of use to HMO are the Bridgwell Centre, Bracknell, RG12 7HA and Heathlands, Crossfell, Bracknell, RG12 7RX. It is noted that the Local Plan considers that it is not necessary to allocate further C2 or C3 provision but it is essential that further

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reviews of the existing position in terms of bed spaces is carried out. Reference should also be made to Policy LP21: Protection of Existing Housing Stock and Land.

Gladman (ID1026) Supports intentions of the Policy. The provision of specialist housing to meet the needs of older people needed to be reflected to a positive policy approach. A robust understanding of the scale is this need across the Borough needs to be established.

Such schemes differ from traditional sheltered/retirement accommodation and provide internally accessible communal facilities residents’ lounge, library, dining room, guest suite, quiet lounge, ICT suite, assisted bathroom, internal buggy store and changing facilities, reception and care managers office and staff facilities.

Reference made to recent research conduced by Irwin Mitchell (https://www.irwinmitchell.com/newsandmedia/2017/july/two-thirds-of-local-authorities-failing-to-prioritise-housing-for-olderpeople-jq-25948).


Support the Policy.

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Responses to Policy LP23 (Self Build and Custom Built Housing)





Binfield Parish Council (ID275) Support self build and custom build, and the diversity in housing that will be provided, as an alternative to the limited variation and imposed compromises of standard developments.

Binfield Parish Council (ID275) Wish to see measures to ensure that plots are made available to self-builders at a reasonable price. Possibly with a public auction, in which no bidder may buy more than 1 plot, or an auction for those on the Bracknell Forest Council self-build and custom house build register.

Binfield Parish Council (ID275) Would like to see more single storied dwellings built for older and/or disabled people and self-build or custom build seems to be a suitable, even more so when provided by the Council or a housing association. Would like to see aggressive marketing of the self-build or custom build plots to housing associations in order to maximise the opportunities provided. The developer should only be allowed to build on the plots once all other avenues for development have been exhausted.


No comment.


Policy supported.


Tuffley (ID991) Considers self build preferable. Wallen (ID834) 5% seems a high figure. Wallen (ID834) How will it be ensured that self builds have consistency with

streetscene of other housing? Wallen (ID834) There should be something that ensures the building is occupied by

the owner for a minimum of 3 years to avoid profiteering. Collings (ID1079) Supportive of self build and custom build but the allocation of large

sites for these will need careful control to ensure good planning and design and to avoid piecemeal and out of character designs.



Support the encouragement of self-build, but do not consider the requirement for sites over 200 to provide up to 5% serviced plots to be justified or consistent with national policy. Para. 57-024 of the PPG sets out a variety of approaches that need to be considered, and do not consider the Council has provided evidence of consideration of these approaches.

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Do not consider the policy to be consistent with the third bullet point of para. 57-025 of the PPG, which relates to encouraging self-build and custom housing The approach taken moves beyond encouragement and requires land owners to bring forward plots. Suggest Policy is deleted and is replaced with a policy which seeks to encourage provision of self-build plots on larger sites.

Part iii) of the policy is not sound. The Council expects affordable housing requirements on sites to include self-build and custom units, and as such they should not be offered to the Council or housing association prior to being built out by the developer.


Noted that a number of other authorities progressing local plans propose these type of policies, strongly advise the Council not to follow this approach, as there is no national policy requirement or guidance which supports this (NPPF, draft NPPF do not refer to this).

Do not consider that the evidence referred to in para. 13.3.4 provides a robust evidence base to support the policy. Number of people on the Bracknell register demonstrates the demand is marginal and does not support the policy.

Practicalities of supplying serviced plots needs to be considered. Health and safety site management implications would mean that individuals and individual contractors are unlikely to be able to access the serviced plots until the wider site is complete – impact on delayed delivery of housing.

Part iii) proposed marketing period is considered too long and risks delaying delivery. Requirement to offer plots to the Council or Housing Association for first refusal is acceptable but the wording should be clarified to confirm that this would be at market value.

Policy requires the dwelling to be completed within 3 years of purchasing the site. It is difficult to see how this could be enforced and what would happen if an owner failed to meet this requirement.

Similar wording has been discussed at the recent Cotswold Local Plan examination. The policy accepted that the maximum of at least 5% should be subject to demand and if, following a marketing period there was no take up, the plot could be offered to the Council/RSL at market value for a period of time before being built out as an open market unit.

In relation to the above, suggest amendments to the Policy as follows:

Development proposals for more than 200 dwellings on sites of 6 hectares and above should provide at least up to 5% of dwellings, subject to demand on the Council’s Self Build Housing

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Register, as serviced plots for sale as to custom builders units.

The delivery of housing on these plots will: i) be developed in accordance with an agreed design code; ii)be required to be completed within 3 years of a custom builder

purchasing a plot; and iii) where plots have been made available and marketed

appropriately for at least 12 months and have not sold, the plot(s) will can either be expected to remain on the open market as self-build or custom build or be offered to the Council or a Housing Association at market value for a period of 28 days before being built out by the developer as open market dwellings.

Development proposals for individual self-build or custom build house building below this threshold will be assessed on their individual merits in the light of the prevailing policies of this plan and any other material considerations.

Boyer on behalf of Bloor Homes Ltd (ID927)

No evidence has to how the Council has derived the requirement on 5% on all sites over 200 or 6ha., therefore unjustified Based on the sites listed in LP3, six sites would exceed the LP23 threshold, generating c. 112 serviced plots which vastly outstrips demand.

Also unclear whether the fact that self-build units are not required to contribute towards CIL/s.106 (as set out in the NPPF) has been taken into account in deriving the 5%.

Provision of 5% also has potential implications in terms of viability, particularly sites with higher infrastructure costs or other abnormal costs.

Therefore suggested amendments to the Policy as follows:

“Development proposals for more than 200 dwellings on sites of 6 hectares and above should provide at least 5% of dwellings as serviced plots for sale to custom builders, subject to viability and all other material considerations”.

The delivery of housing on these plots will:

• be developed in accordance with the agreed design code; • be required to be completed within 3 years of a custom

builder purchasing a plot or prior to completion of that phase by the developer, whichever is sooner; and

• Where plots have been made available and marketed appropriately for at least 12 months and have not sold, the plot(s) will be expected to remain on the open market as self-build or custom build or be offered to the Council or a

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Housing Association before being built out by the developer. The un-sold plot(s) should be built out prior to completion of that phase by the developer.”

Gladman (ID1025) Requirement to provide 5% as services plots is fixed and not flexible, nor relates to any published evidence on need/demand. Supporting text refers to only 44 individuals across the borough having registered an interest. Consider the policy to be inconstant with the PPG (para. 57-025), and should set out a pro-active approach to enabling self build and custom building.


Paragraph 6.56 and 6.57 Reference is made to custom build and self-build dwellings, the principle of which is encouraged through the Draft Revised NPPF. It is however important that consideration is given to the need for such plots, before their inclusion is required.


The requirement for the provision of self-build and custom build homes should be dependent upon the need for such units (as referred to at 6.57). If the need is not present, then such provision will be unnecessary and disruptive to the eventual development of a site.

Proposed Change First line of Policy LP23 to be amended as follows; ‘Development proposals for more than 200 dwellings on sites of 6 hectares and above should provide at least 5% of dwellings as serviced plots for sale to custom builders, if the Self Build and Custom Housebuilding Register indicates there will be sufficient demand for such properties at the location.’

Alfred Homes (ID 1441) Policy is not justified or effective (ignores para. 025 of PPG ID: 57-025-201760728.) Threshold specified is not based on evidence. No consultation with landowners or consideration of how the disposal of the public-sector estate can potentially contribute to the supply of self-build provision.

Bewley Homes (ID 1477) Consideration needs to be given to the need for such plots, before their inclusion is required, as referred to at 6.57.

Proposed Change First line of Policy LP23 to be amended as follows; ‘ Development proposals for more than 200 dwellings on sites of 6 hectares and above should provide at least 5% of dwellings as serviced plots for sale to custom builders, if the Self Build and Custom Housebuilding Register indicates there will be sufficient demand for such properties at the location.’

Persimmon Homes North Object to the Policy. Question whether the Council has fully London (ID1407) evidenced and justified the need for the policy (the 2016 SHMA

states only 17 people have registered an expression of interest in self-build). Further work is required.

Imposing a strict percentage of dwelling plots to be allocated to self-build will hinder the efficient delivery of housing on large sites in

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general.

Where plots are not sold, it is important that the Council’s policy is clear as to when these revert to the developer. Suggest the policy states if a plot remains unsold within 6 months of being offered on the open market, it should revert back to the developer to be delivered as part of the overall scheme.

Boyer on behalf of Jordan Construction (ID1364), W J Channing & Sons (Woking) Ltd (ID1383)

No evidence has to how the Council has derived the requirement on 5% on all sites over 200 or 6ha., therefore unjustified. Based on the sites listed in LP3, six sites would exceed the LP23 threshold, generating c. 112 serviced plots which vastly outstrips demand.

Also unclear whether the fact that self-build units are not required to contribute towards CIL/s.106 (as set out in the NPPF) has been taken into account in deriving the 5%.

Provision of 5% also has potential implications in terms of viability, particularly sites with higher infrastructure costs or other abnormal costs.

Therefore suggested amendments to the Policy as follows:

“Development proposals for more than 200 dwellings on sites of 6 hectares and above should provide at least 5% of dwellings as serviced plots for sale to custom builders, subject to viability and all other material considerations”.

Consider part of draft policy confusing does not clearly direct the developer as to the steps they can take if a plot remains unsold after 12 months. For instance, how long do any plots have to remain on the open market before the developer can build them out?

Consider that since qualifying development sites will already be required to provide 35% affordable housing (Policy LP24), and that self- and custom-build housing is a form of market housing (not affordable housing), this requirement is also unjustified.

Considers draft Policy should allow for any self-build plots to revert directly to the developer after 12 months should there be insufficient demand for such plots, which would minimise delays to the delivery of schemes and reduce uncertainties in the build programme for developers.

Turley on behalf of Bloor Whilst no objection to the aspiration to deliver such housing, do not Homes Ltd (ID1431), Knight consider the proposed policy to be justified or effective. The and Alfred Homes (ID1441) approach within the policy is not based on evidence. There has

been no consultation with landowners/developers or consideration of how disposal of public-sector estate can potentially contribute to the supply of self –build provision.

Barton Willmore on behalf of Willson Developments Ltd

Not consistent with para 57-025 of the PPG – which refers to local policies being a possible approach for supporting self/custom build.

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(ID951) Draft wording suggests the NPPF/PPG requires developers to provide self-build as part of s.106 obligation.

The policy provides no clarity on the timescale being provided after which a developer would get to build the dwellings out.

Therefore, consider the policy should be removed, or revised to take account of the above.


Not consistent with para 57-025 of the PPG – which refers to local policies being a possible approach for supporting self/custom build.

Draft wording suggests the NPPF/PPG requires developers to provide self-build as part of s.106 obligation.

The policy provides no clarity on the timescale being provided after which a developer would get to build the dwellings out.

Therefore, consider the policy should be removed, or revised to take account of the above

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Responses to Policy LP24 (Affordable Housing)





Binfield Parish Council (ID276) Strongly support the provision of a large proportion of affordable housing. The limitation on the viability of a development which provides affordable housing is justified in some cases, but can be a loophole which is exploited. Monitoring of the original planning application is key. Where developers declare that a significantly lower proportion is required, there should be some mechanism whereby outline planning can be revoked.

Binfield Parish Council (ID276) Must find more creative ways to provide housing stock for younger people to buy their first homes as well as other groups needing a specific type of housing. Would like the Borough to consider the delivery of public housing. With plans for redevelopment of the town centre, there must be some land in the council’s control, which could be used to provide affordable, high quality social housing.


No comment.

Warfield Parish Council (ID687) Would like to see a mix of tenure types on site and would encourage BFC to seek provision on development sites. Would like to see clear and unambiguous report of number of affordable housing units delivered annually as part of LP24.

Bracknell Town Council (ID438) There is need for genuinely affordable housing in Bracknell Town. 35 percent is welcomed, but needs to be adhered to.


Policy partially supported.

Currently policy relates to 25%, and over last 10 years, 27% has been secured. Developers using viability for non-delivery of affordable is increasing. Why set a figure that cannot be met.


Affordable housing will need to be sustainable and use more renewable energy to reduce costs for tenants.


Brett (ID210, 211) Affordable housing is for rental projects, not for people who can actually afford to buy.


The policy allows financial contribution to off-site provision as an alternative to provision. However, lacks any commitment that these homes will ever be available. Recent question to BFC suggests affordable homes is about 5% below the target. Part of the reason may be developers being permitted to reduce the percentage in return for a financial contribution. Suggest amending wording of the policy: “Contribution to offsite provision of affordable housing shall be permitted when such offsite provision is identified, allocated, and fully funded”.

Murphy (ID635) Concerned that policy allows ‘wriggle room’ for developers in lieu and use the cost of infrastructure costs to decrease or not provide affordable housing. The site allocation process does not take

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account of this and ensure sites are allocated that will deliver affordable homes.

Skudder (ID662) Plan requires 35% affordable, previous developments in the area have fallen short of affordable housing targets. What is to suggest this will not happen again? If developers do not comply, proposals, cannot be sustainable or deliverable.

Wallen (ID835) Priority should be given to those living in the new build area/parish. Butcher (ID981) Policy supported, however does not consider enforceable. This

policy needs to be proactively pursued, written into conditions when plans are approved. The viability elements should be demonstrated before planning permission is granted, and what is granted in terms of affordable must be built.


Questions how affordable housing is defined.

Tuffley (ID1009) 35% is too low to meet need for affordable housing.

Collings (ID1080) Concerned that the target of 35% of net new homes will not be achievable anywhere (as occurring in Warfield now) due to the cost of infrastructure associated with this Plan. The viability testing as required in paragraph 13.4.6 is key.

Neill (ID1336) The policy allows too much leverage for developers to vary the mandatory percentage of affordable housing. The amount should be fixed at 35%. The developers at the Heatherwood hospital site must make good the Government promise to give hospital workers the ‘first refusal’ on affordable properties built there.


Broadmoor Hospital (ID244) Supports aim to boost supply of housing to deliver more affordable homes but it should not be sought at the cost of investment into healthcare. The masterplan for SA4 is predicted on land sales helping to fund the enhanced healthcare and the Broadmoor Estate is highly constrained (listed building, SPA and requirements for SANG and SAMM payments). A one size fits all policy without taking constraints of each allocation into account is not supported. The 35% affordable housing is over ambitious, not deliverable and will have a detrimental impact on the development.

Broadmoor Hospital (ID244) Where affordable housing is provided on surplus NHS land it should be for healthcare staff and other NHS workers in line with the 2017 Naylor Review.

Broadmoor Hospital (ID244) The proposed viability tests are acknowledged and supported. The proposed 35% appears to be based on needs (the SHMA indicates there is a net affordable housing need of 227 units per annum which represents 35% of overall housing need) rather than evidence the target is deliverable. The drop in actual provision by 22% in the BFC Authority Monitoring Report strongly suggests it is not deliverable.

Boyer Planning for JPP Land/Hodge Developments

Recognise the importance of affordable housing as part of a sustainable and balanced community, and the flexibility should by

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(ID803) the draft Policy by supporting provision either on-site or off-site or through a financial contribution.


Note that the Council proposes to increase current requirement from 25% to 35%. Consider this may place undue pressure on developers and is likely to threaten the viability of proposed development, therefore essential the Council has robust justification for the planned increase.

Welcomes the recognition within the draft Policy that there may be cases where the delivery of 35% affordable housing would prejudice the viability, and in such cases the level of affordable housing may be varied. However, it is importance not to set the percentage too high for affordable, which will lead to submission and assessment of unnecessary viability appraisals, which will delay determination of planning applications/delivery of housing.

Woolf Bond on behalf of Hodson Developments (ID916-922), JPP Land and Neal (ID893), JPP Land (ID910), Flavia Estates Ltd & JPP Land Ltd (ID 900), Warfield Park (ID1291)

Object to increase in affordable housing from 25% to 35%. No robust evidence that this can be viably achieved. The Council’s Viability Assessment (prepared by BNP Paribas in July 2017) (paragraph 5.10) indicates that achieving 35% affordable housing is only feasible in the longer term, assuming property values increase above £3,500m2. However, table 3.4.1 of the Viability Assessment indicates that this is above the average achieved in Bracknell town. This is a flawed approach to assessing viability as it ignores potential increases in build costs (materials and/or labour) which will negate any increase in value. Further, the viability assessment does not robustly demonstrate that dwellings would be viable taking account of the mix of units (policy LP25) together with internal space standards (policy LP20).


Previous representations at Issues and Options stage referred to requesting viability testing in respect of affordable housing, the draft Policy now includes this requirement, which is supported.


There is a risk that the Council’s approach to affordable housing will lead to developments being unviable. It is important that when setting affordable housing targets the Council does not push at the margins of what is viable and ensure that changes in costs or values do not require frequent changes to policies (paragraph 10-008 of PPG).

The Viability Assessments shows that in a number of scenarios, 35% will be unviable. Recommend the Council’s considers reducing its affordable housing requirement to better support the delivery of the proposed levels of development across the Borough.

Tetlow King on behalf of Rent Plus Ltd (ID769, 770)

The Council should ensure the policy complies with national policy to include the proposed requirements for:

• the amended definition of affordable housing setting out a fuller range of affordable home ownership tenures, including rent to buy;

• at least 10% of major residential development proposals to

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be made up of affordable home ownership tenures where this will meet identified local needs; and

• provision of entry level exception sites.

Whilst the policy does not specify a mix of tenures, it would be useful for the supporting text to confirm the Council will support the delivery of the full range of affordable as set out in the draft NPPF.


Object to the policy. The Policy requires 35% affordable. The SA9 allocation is subject to the Warfield SPD, adopted in February 2012, which includes a requirement for 35% affordable housing. To change the threshold at this stage could have implications for delivery of allocations.

Suggest amendments to the Policy as follows:

In order to secure a mix of housing types and tenures the Council will seek the provision of 35% of net new homes on sites of 11 or more dwellings to be affordable either by means of on-site provision, off site provision or by means of a financial contribution. Where it can be demonstrated that the delivery of affordable housing would prejudice the viability of the development or the provision of other essential infrastructure required to serve the development this requirement may be varied. Sites already progressing as part ofthe Site Allocations Local Plan that are the subject ofSupplementary Planning Documents may continue as outlined within the Supplementary Planning Document.

Boyer on behalf of Bloor Homes Ltd (ID926)

Welcome the flexibility shown in the Policy in terms of provision either on-site or off-site, or through a financial contribution, but note the proposed increase from 25% to 35%. Consider this will place undue pressure on developers and is likely to threaten viability of some developments.

Delivery of affordable homes is linked to CIL and s.106. Without a review of CIL viability and charging, the amendments to affordable housing levels should not take place. Robust justification required.


The current requirement for the provision of affordable homes is 25% on schemes of more than 15 dwellings. Decreasing the threshold to 11 dwellings is in line with Government policy, but increasing the percentage from 25 to 35% is not. Significantly increasing the percentage requirement is likely to have a negative effect on affordable housing delivery, because it will render some site unviable so that they will not come forward or developers will undertake viability assessments, which will result in developments proceeding with no affordable housing or only a very small percentage.

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Proposed change Policy LP24 should be amended to refer to 25% affordable housing provision instead of 35%.

Alfred Homes (ID1439) Proposed requirement represents a significant uplift - no-precedent for it in the Borough. Has not been tested. May impact on viability and delivery of new housing.

The Council’s Viability Assessment states that a target of 35 per cent affordable housing may be achievable on many development sites. However, paragraph 6.3 of the Assessment indicates that achieving this higher rate will be contingent on developers not over-paying for sites.

Landowners will inevitably seek to maximise the value of their assets – risk that they may withhold land until a more favourable policy context emerges.

Do not consider that the Viability Assessment has factored in the increased cost implications associated with the ‘Draft Thames Basin Heaths Special Protection Area (SPA) SPD.

Request inclusion of a caveat within the wording of Policy LP24, which allows for the proportion of affordable housing to be varied (at the decision-making stage) on the basis of detailed viability evidence. Additional assessment work is also required to ensure the approach to viability is effective at the Local Plan level.

Persimmon Homes North Support the policy and flexibility of affordable housing being provide London (ID1408) by way of an on-site, off-site or by means of financial contribution.

Support the trigger for affordable housing being based on number of dwellings, rather than total .floor space, or number of bed spaces.

The policy does not include a requirement for tenure split of affordable housing, which should be included.

Support the flexibility of the application of the Policy based on viability, would welcome further detail how viability evidence will be assessed and considered,


Welcome flexible mechanisms for delivery of affordable housing, however concerns raised about impact 35% could potentially have on development viability.

Cites Council’s Viability Assessment (2017) showing a number of scenarios where 35% requirement will make development unviable or push it to the margins of viability in lower value areas. Assessment indicates that such development is only taken beyond marginal viability at values of over £4,200 per sqm, which on the basis of average values across the Borough (set out in Table 3.4.1 of the Viability Assessment); this would affect development across the Borough and in particular the larger strategic sites that are

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required to meet the Council’s housing requirement. Viability Assessment suggests (para 6.5) that in these situations increases in values will address such concerns; but given that the Council is seeking to improve affordability it should not be seeking to rely on increased values in order to ensure the delivery of more affordable housing.

Consider should look to reduce affordable housing requirement to improve affordability and better support deliverability of the proposed scale of development across the borough.

Barton Willmore on behalf of Harrison Housing (ID1059), and Willson Developments Ltd (ID952)

Support the policy.

Turley on behalf of Bloor Concerned that the proposed approach will have a significant impact Homes Ltd (ID1429), Knight upon the viability of sites and negatively impact on the delivery of and Alfred Homes (ID1439) new housing. The uplift from 25% has no precedent in the Borough

and has not been tested in practice.

Concerns regarding approach in the Viability Assessment with referenced to para. 6.3 in terms of the higher rate of affordable housing being contingent on developers not overpaying for sites. In a real world free market, land is worth what someone is willing to pay for it. The reality is such matters are established through complex contractual negotiations.

Additional work is required to ensure the approach to viability is effective at the Local Plan level, in order to establish whether 35% is realistic and achievable without detriment to overall delivery.

Turley on behalf of Berkeley Whilst supportive of the need to ensure affordable housing needs Strategic Land Ltd (ID1476) are appropriately planned for and delivered concern is raised that

the Viability Assessment indicates that development viability in lowest land values areas (largely in the south of the Borough) on medium greenfield sites (Typology 4) and on large greenfield site clusters (Typology 5) at 35% affordable housing (and in some instance 25% affordable housing) becomes marginal or unviable.

In light of this, support the inclusion within the proposed policy wording of the caveat that the proportion of affordable housing may be varied subject to viability considerations, which accords with the requirements of the NPPF. However, further viability work needs to be carried out toward robustly determining if a lower affordable housing requirement across the Borough might be more appropriate to ensure a consistent delivery of sufficient affordable and market housing is achieved during the lifetime of the Plan.


Support the policy.

Boyer on behalf of Luff Developments (ID1329)

Luff recognise the importance of affordable housing as part of a sustainable and balanced community and as sought by draft Policy

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LP24. Welcome the flexibility shown in the draft Policy by supporting the provision of affordable housing through the provision of either on-site, off site or through a financial contribution.

Note that the Council propose to increase the current policy requirement of 25% affordable housing to 35% may place undue pressure on developers and is likely to threaten the viability of some proposed developments. It is therefore essential that the Council has robust justification for the planned increase in affordable housing.

Welcome the recognition in the draft Policy that there may be cases where the delivery of 35% affordable housing would prejudice the viability of development and that in such cases, the level of affordable housing may be varied. It is however important not to set the % too high for affordable housing which will lead to the submission and assessment of unnecessary Viability Appraisals which will delay the determination of planning applications and delivery of housing.

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Responses to Policy LP25 (Housing Mix – Tenure Size and Accessibility)





Binfield Parish Council (ID277) Support the policy providing for a mixture of housing. However, the point as to whether the local infrastructure can support the housing provided is not considered here. It is providing additional local infrastructure that is the key to whether additional housing can create “balanced communities”. Insufficient weight has been placed on this to date and, on the evidence of the Local Plan, will continue to do so.


No comment.

Warfield Parish Council (ID1537)

Supportive of policy.


Why is the housing mix shown in section 13.5 – Housing Mix at Table 6 totally different to the Housing mix shown in the Infrastructure Delivery Plan (IDP) at 2.3 Assumptions 2.3.1 Table 1?

(also summarised in section relating to evidence base – IDP)



Table 6 in relation to the housing mix doesn’t sit with the understanding of the need for smaller homes for single people/young couples. Reference made to comment from L&G (developers of Bucklers Park) in relation to release of Phase1, that the one bedroom apartments sold out overnight. Request the Council reviews and verifying the SHMA findings which covers a large area, both urban and rural, and whether they are applicable where developments are proposed in villages around Bracknell.

Gierth (ID324) The policy refers to requirements for fewer than 10 units, and 20 or more units. What is the policy for between 10 and 20?


Welcome the inclusion of the housing mix within supporting text rather than main policy (previously made a representation on this point at the Issues and Options stage).

Jennings (ID1181) A ‘one size fits all’ policy would not be appropriate in all instances since some sites (such as War 9 and War 10) would be better integrated into the area if they were high value and low density.

A and M D’Aubyn (ID995) Four or five bedroom houses are the builders preference as these offer the most profit, but increasing number of single people and couples without children. The percentage of social houses is not enough and the Council should challenge them to build more two bedroom terraces, if necessary selling them at market values. The argument that terrace houses do not fit the ambience of a village often used by the planners is specious.

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Recognises the importance of providing a mix of housing sizes, tenure and flexibility, and welcomes the flexibility included within the Policy. Whilst it is recognised that the evidence base which supports the Policy will be kept under review, it is important that when determining variation from the draft Policy, regard is had to market conditions and the sites location. Therefore the following amended is suggested: “ …..In determining any variation from this policy the Council will have regard to: i. The appropriate mix for the site’s size and location; ii. The most up-to date evidence on local housing needs and market conditions; and iii. For conversions, physical factors limiting a particular mix; and iv. Site specific viability.”


Do not consider that the need for the optional technical standards (as required by para. 56-007 of the PPG) has been demonstrated or provided in the Council’s evidence. (Should include the likely future need for housing for older and disabled people, the accessibility and adaptability of existing stock, the different needs across tenure and the overall impact on viability). Note that the viability study has included within its costs the requirement for Parts M4(2) and M4(3) to be applied, however no analysis of the need for more accessible homes and how this will vary across tenures nor the numbers of homes that are already accessible or are likely to be made accessible using the disabled facilities grant.

Part iv of the policy is not consistent with national policy as it requires all homes to be wheelchair accessible and meet part M4(3) of the Building Regulations. PPG is clear that the requirement for wheelchair accessible homes should only applied to those dwellings: “where the local authority is responsible for allocating or nominating a person to live in that dwelling” (para.56-010).

Tetlow King on behalf of Rent Plus Ltd (ID771)

Policy should be amended as set out below:

i. All residential developments, including conversions of more than 10 net dwellings will be expected to provide a mix of dwellings and tenures reflecting the requirements of Table 6 'Housing Mix' in the supporting text to this Policy or any more recent evidence published by the Council.

In determining any variation from this policy, the Council will have regard to: i. The appropriate mix for the site’s size and site specific constraints; ii. The most up to date evidence on local housing needs; iii. For conversions, physical factors limiting a particular mix; and, iv. Site specific viability.

Requirements such as that set out in Table 6 set an unnecessary

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expectation for all developments to fall within the set mix, even with the 5% allowance. To enable developments to come forward that truly reflect site specific constraints, local housing need and the need to deliver sound placemaking the Council should allow for case-by-case negotiation.


Disparity between required mix in the policy and the mix required at para. 5.11 of the Warfield SPD. Recommend that the sites already progressing as an allocation through the Site Allocations Local Plan, and guided by an adopted SPD continue on the basis of mix already outline, therefore suggest amendments to the Policy as follows:

Proposals will be supported which include a mix of housing to meet existing and future housing needs as set out in the most up to date evidence.

iv) All residential developments, including conversions of more than 10 net dwellings will be expected to provide a mix of dwellings and tenures reflecting the requirements of Table 6 'Housing Mix' in the supporting text to this Policy if not an allocation in the Site Allocations Local Plan guided by an adopted Supplementary Planning Document or any more recent evidence published by the Council. v) Developments of fewer than 10 units will be encouraged to provide a

mix of unit sizes. vi) All new build dwellings will, as a minimum, be constructed in

accordance with the requirements of PartM (4) Category 2 – Accessible and adaptable dwellings of the Building Regulations 2010 (Approved Document ‘M’ – Access to and use of Buildings – dwellings 2015) and any subsequent updates. iv. On developments of 20 or more dwellings, at least 5 % of dwellings will be constructed in accordance with the requirements of Part M(3) Category 3 - Wheelchair user dwellings of the Building Regulations 2010 (Approved Document ‘M’ – Access to and use of Buildings – dwellings 2015) and any subsequent updates. In determining any variation from this policy the Council will have regard to:

i. The appropriate mix for the site’s size; ii. The most up to date evidence on local housing needs; iii. For conversions, physical factors limiting a particular mix; and,

iv. Site specific viability.

Gladman (ID1024) The Council needs to be able to demonstrate through robust evidence, the justification and rationale for the requirement that is being proposed through this policy relating to the introduction of optional standard M4(2). At present, do not consider this has been provided. Not clear how the proposed requirement relates to future needs within the area, whether the adaptability of existing housing has been considered, whether needs across different tenures has been taken into account, or whether consideration has been given to the impact that the requirement will have on the overall viability. The Council must ensure that its policies relating to the introduction of any optional technical standards are consistent with the provisions set out in the PPG.

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Bewley Homes (ID 1488) Para 13.5.3 of the DBFLP confirms that a rigid application of the mix requirements may not be appropriate in all cases - this should be incorporated within the policy wording. Also need a distinction between sites of less and more than 10 units as the policy currently does. If there is a strong need for 2 and 3 bed properties in a location, is it reasonable to allow a scheme of 9 x 5 bed detached properties?

With regards reference to Part M, paragraph 56-007 of the PPG requires local authorities to demonstrate the need for the optional technical standards to be applied to new homes. The need for all new homes to be built to such standards, as required by criterion (iii), has not been shown by the Council, and is therefore not justified. Once it is established what proportion of new homes need to be built to such standards, then an appropriate percentage figure can be applied to the policy.

With regards to criterion (iv) relating to wheelchair user dwellings, question what evidence the Council has to propose a figure of 5% of all dwellings on larger schemes.

Proposed change to Policy LP25

(i) All residential developments will typically be expected to provide a mix of dwellings and tenures reflecting the requirements of Table 6

‘Housing Mix’ in the supporting text to this policy or any more recent evidence published by the Council.

(iii) (? - to be justified)% of all new build dwellings, as a minimum, will be constructed in accordance with the requirements of Part M (4) Category 2…………….

(iv) On developments of 20 or more dwellings, at least (? – to be justified) % of dwellings will be constructed in accordance with the requirements of Part M(3) Category 3

Persimmon Homes North Size and tenure. The Policy details specific requirements for the London (ID1409) size and tenure of housing in residential developments of more than

10 net dwellings. However, the evidence does not fully support and demonstrate the need for this specified mix to apply to developments of this size. Further evidence should therefore be provided to demonstrate that this mix is required for developments of 10 or more dwellings in order for the policy to be effective and justified. Whilst agree with the approach that the size and tenure of housing should meet current and future needs, consider that this aspiration should be balanced against a requirement for development to be consistent with local character.

Accessibility. Object to this aspect of the policy which seeks to impose standards relating to accessibility by wheelchairs. In line

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with paras. 174 and 177 of the NPPF, LPAs should assess the cumulative impact of policy burdens so that implementation of the plan is not at risk. Evidence is required to demonstrate need for additional standards, and the impact should be part of the Local Plan Viability Assessment. Do not consider the 2016 Plan viability to sufficiently assess the knock on effect on house prices, as a result of increased build costs. Evidence should consider current living trends.

Density. The policy does not provide guidance on the density of residential development which is a key factor in ensuring efficient and effective use of land. Therefore suggested amendment to the policy as follows:

• Achieve a density of development which is appropriate to the location and context of the site


Unclear from the supporting evidence base published alongside the Draft Local Plan consultation whether the Council has considered the full range of evidence required by the PPG to justify policy requirements. Unjustified based on evidence available at the time.

Consider that in addition to considering a site’s size, the existing character of the area in which the site is located is also often a material consideration when determining an appropriate housing mix for a site, which may justify a variation from the mix set out in Table 6. It is therefore recommended that this be included in the list in the Policy.

Barton Willmore on behalf of Harrison Housing (ID1058), Willson Developments Ltd (ID954)

Support the policy.


Support the policy.

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Responses to Policy LP26 (Travelling Populations)

Responses to Policy LP26 (Travelling Populations)




Binfield Parish Council (ID278) Safeguarding of existing sites is supported. Binfield Parish Council (ID278) No information has been provided as to proposed locations for the

additional five Gypsy and Traveller pitches. Crowthorne Parish Council (ID415, ID416), Warfield Parish Council (ID1538)

No comment.


The PPTS sets out that local plans should include criteria-based policies to provide the basis for decisions in the event that applications for pitches come forward and is clear that such policies should be included in plans whether there is an identified need or not –paragraph 11 states: ‘Where there is no identified need, criteria-based’ policies should be included to provide a basis for decisions.

Criterion 1 of LP26 specifies that there must be an identified need in order for applications to be considered acceptable. WBC considers this to be contrary to national policy.

Historic England (ID781) Welcome reference to historic assets in criterion iii but the aim should be to avoid harm to heritage assets not simply to mitigate it (see paragraphs 126 and 132 of the NPPF) Criterion iii should be reworded as suggested.

Environment Agency (ID1266) At Issues and Options consultation, supported intention to ensure new or extended traveller sites would not be supported in areas at flood risk. Therefore, cannot support omission of this from Policy LP26, especially in light of Policy LP40 which refers to traveller sites in paragraph 18.1.4. As a minimum, link should be made that this policy should be read in conjunction with Policy LP40.

While it is ensured that impacts are mitigated, housing sites must be sequentially tested in accordance with the NPPF, ensuring they are in areas at lowest flood risk (avoidance). If it is not intended to allocate traveller sites within the local plan (which would undergo the sequential test) this requirement must be within the policy.

A link should be made to Objective B. Sandhurst Town Council (ID1598)

Policy supported.


Bretet (ID212, 213) How will this be controlled? Tuffley (ID992) States comments to make, but no comments provided.


None received.

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Responses to Chapter 14: Employment Areas - General

Responses to Chapter 14: Employment Areas - General




Surrey Heath (ID108) Comments relating to para. 14.4.5: concerns regarding opportunities to meet future comparison goods needs by developing further sites on the edge of Bracknell town centre. Any future approach to comparison goods floorspace provision in the town centre would need to ensure that this did not result in a change to Bracknell’s classification in the retail hierarchy.


No proposed additional employment within the proposed sites. Keen to promote local businesses and work with them to ‘grow’ their businesses bringing local employment opportunities.


Jennings (ID1182) Employment development outside employment areas should not be supported. Land outside employment areas should be reserved for housing.



None received.

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Responses to Policy LP27 (Employment Areas)

Responses to Policy LP27 (Employment Areas)




Binfield Parish Council (ID279) Agree that defined Employment Areas are desirable. This is on the basis of evidence from businesses that not having defined areas would be detrimental to businesses and would be likely to lead to relocation and the loss of jobs. Strongly supports the protection of commercial space in existing employment areas from irreversible conversion to residential use for short term profit. When they’re gone, they’re gone.


See comment on Section 7 (ID398).

Warfield Parish Council (ID688) Supportive of policy and need for defined employment areas. Sandhurst Town Council (ID1126)

Policy supported, suggest an amendment to include: “development which provides the necessary infrastructure including public transport services, pedestrian and cycle facilities”


None received.


Hewlett Packard Enterprise (ID906)

Policy LP27 does not provide sufficient flexibility to be responsive to changing market needs or site-specific circumstances and housing needs. May be appropriate to accept a reduced marketing period or marketing may be unnecessary in light of local trends.


Support the Policy.

Consider that as a significant employer within the Borough, Jealott’s Hill should be included as a defined Employment Area, thereby benefiting from the same support afforded by the draft Policy.

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Responses to Policy LP28 (Employment Development outside Employment Areas)

Responses to Policy LP28 (Employment Development outside Employment Areas)




Binfield Parish Council (ID280) Agree with the principle of creation of employment, commerce and/or light industry, within residential or outside defined employment areas, provided conditions include sufficient safeguards against nuisances and physical impact upon residents. We see a particular advantage in employees among local residents being able to walk to work rather than having to drive to an industrial area.



Warfield Parish Council (ID689) Supportive of policy but consider section detailing unacceptable impacts needs further definition to ensure clarity to officers implementing policy.


Policy supported, suggest an amendment to include: “v. will provide necessary infrastructure including public transport services, pedestrian and cycle facilities.”


Jennings (ID1174) Employment development outside employments areas should not be supported. Land outside employment areas should be reserved for housing.


Gladman (ID1023) Supports the Policy. Important that the policy approach reflects the significant weight that should be placed on the need to support economic growth and productivity in the planning system.


Support the Policy.

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Responses to Policy LP29 (Smaller Businesses)

Responses to Policy LP29 (Smaller Businesses)




Binfield Parish Council (ID281) Support modest development to facilitate expansion of existing small businesses and assist with creation of start-ups within established commercial areas, to obviate the need to build or find accommodation elsewhere. Agree that such expansion should not compromise the integrity of an established employment area.



Warfield Parish Council (ID690) Recognise important role smaller businesses play to the health of local and national economy. Important smaller units are protected where necessary from redevelopment to other uses.


Policy supported.


Wallen (ID836) It would be good to provide small serviced office areas with refreshments so that home workers can hold meetings/meet with others to prevent social isolation.

Neill (ID1337) Propose deletion of iii), as this gives too much leverage to already powerful large retailers. Propose setting targets on the number of units/floorspace to encourage small business, independent and charitable retailers, and business rate incentives.


Leigh (ID76) No justification in supporting text for the loss of smaller business threshold of 500sqm. No wording in the policy to allow for any exception to this blanket approach, such as circumstances where an existing business unit under 500sqm should or cannot remain (uneconomic, constraints on the site, condition of the building, market etc). Other policies in Development Plans allow for a period of marketing over a year to take place, or take account of any benefits arising for a loss. Draft Policy LP34 (in relation to protected community facilities), includes a provision, which could be included in Policy LP29. Policy should therefore be reworded to set out circumstances for exceptions to the final paragraph of the Policy.


Support the Policy.

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Responses to Policy LP30 (Development in Bracknell Town Centre)

Responses to Policy LP30 (Development in Bracknell Town Centre)




Binfield Parish Council (ID282) Agree with the Town Centre policy, whereby prime retail shopping facility should not be compromised by conflicting and/or inappropriate development.

Binfield Parish Council (ID282) Support the utilisation of underused space in buildings as affordable residential apartments, but only where the change could be reversed as and when demand for commercial use increases.



Warfield Parish Council (ID691) Supportive of policy. Consider further development within town centre needs to ensure viability of commercial activity and ensuring right environment to make area attractive to residents/businesses/ visitors. Other supporting infrastructure (e.g. appropriate street lighting) needs to be incorporated. Consider necessary transport infrastructure e.g. public transport, cycle and pedestrian facilities, core to delivery of development within town centre.


Policy supported.



Para. 14.4.6 in relation to a range of acceptable uses including cultural should include reference to community hall.

Consideration should be given to public conveniences (separate to those inside stores), a community notice board, and retain/upgrade the community hall at Cooper’s Hill.

Consideration should also need to be given to a cycle route through or around the town centre.

Brett (ID214, 215) Lexicon project hasn’t added value. Sims (ID464) New town is working. Further shops needed (Five Guys, Star

Bucks, Eat, Café Nero, Disney Store, Themed Bar and more designer shops), in order to attract people from other towns.

Sims (ID464) Turn the library into more shops/restaurants. Finish the deck area. Gunn (ID1205), Fazey-Gunn (ID1242)

Infrastructure needs to be improved in and around the town centre during rush hour, as traffic still queues through Bracknell as it links the M3 and M4. Traffic in and around Wokingham also adding to traffic.


None received.

Responses to Policy LP31 (Out of Centre Development)

Responses to Policy LP31 (Out of Centre Development)




Binfield Parish Council (ID283) Agree that retail, office or leisure proposals that are likely to cause heavy traffic flow should be supported outside of the town centres, to dilute weight of traffic to the centres.


Majority of working residents outside of Bracknell Town commute to work outside the Borough. There has been a lack of control of developers converting business premises into flats and apartments. More provision should be made for allocation of business space in the towns and villages.

Warfield Parish Council (ID692) Supportive of policy. Bracknell Town Council (ID439) Supportive of policy. Sandhurst Town Council (ID1129)

Policy supported, amendment suggested: Include paragraph additionally Proposals should not result in unacceptable harm to : Highway safety Residential amenity


Wallen (ID837) 14.5.1. Typo ‘has’ should be ‘have’.



The lower threshold of 1,000sqm for an impact assessment (compared to the 2,500sqm as set out in para. 26 of the NPPF) is welcomed.


Acknowledge that the Peel Centre is designated as edge of town centre, with primary and secondary shopping frontages.

MRPP on behalf of Tesco Stores Ltd (in respect of storestore at The Meadows) (ID449/450)

Concerned regarding the absence of a policy dealing with the sequential test (as contained in para. 24 of the NPPF). Policy CS22 of the Core Strategy deals with this, but would be replaced by Policy LP31 once adopted, therefore no local policy on this matter.

Responses to Chapter 15: Local Retail and Community Uses - General

Responses to Chapter 15: Local Retail and Community Uses - General




Warfield Parish Council (ID693) Supportive of objective to plan for the continued regeneration of Bracknell Town Centre.


None received.


MRPP on behalf of Tesco Stores Ltd (in respect of store at The Meadows) (ID449/450/1320)

Absence of sequential test is a concern given that Core Strategy Policy CS22 ‘Out of Town Centre Retail Development’ will be replaced with Policy LP31 leaving no local policy to deal with the sequential approach. Recommend an additional policy, similar to the sequential test set out in Policy CS22. If the retail hierarchy is not amended, any new sequential test policy should be clear about which centres are the ‘defined centres’ for the operation of this policy. Because of the more than local importance of the services and facilities provided at The Meadows, ‘defined centres’ must clearly include ‘out of centre’ centres.

I

Responses to Policy LP32 (Changes of use within defined Retail Centres)




Natural England (ID117) Note that the Bagshot Road Superstore site sits partially within the 400m exclusion zone. Would not want additional car parking spaces provided for this site (unless they were for private use only and secured using measures such as barriers/security personnel).

Binfield Parish Council (ID284) Would like to see a way of preventing excessive use of shops in local parades as bookmakers and/or takeaways. Financial incentives should be used, if possible, to encourage small, independent retailers.

Binfield Parish Council (ID284) Further shopping parades/clusters should be encouraged on larger new developments.

Binfield Parish Council (ID284) Support the utilisation of underused space in buildings, such as flats above shops, as affordable residential apartments where it does not detract from the primary retail use of the property.

Crowthorne Parish Council Required to protect retail/commercial property from conversion to (ID418) residential. Warfield Parish Council (ID693) Supportive of policy and recognise retailers are having to adapt to

changing shopping habits/ retail units may need to change to reflect this. Supportive of use of upper vacant floors for residential as long as does not result in ‘dead frontage’ on ground floor.

Sandhurst Town Council Policy supported. (ID1601)


Murphy (ID636) Para. 15.1.1, 15.1.3, 15.1.4. Northern parishes with allocations of new housing are not well served by local retail centres/no plans to provide further on a sufficient scale.


MRPP on behalf of Tesco Given range of facilities and services provided (including M&S) The Stores Ltd (in respect of store at Meadows is more akin to a Town Centre (well located, served by The Meadows) frequent buses, and relationship to the Royal Military Academy). (ID449/450/1320) These aspects acknowledged in the 4th bullet of para. 15.1.2.

The Meadows has been identified as an out of centre retail centre. Whilst this identifies The Meadows as a centre, it fails to represent the full role and function of The Meadows, which consider to be comparable (in terms of total floor space and breadth of facilities) with centres higher up the hierarchy, and is consistent with the definition of a district centre.

Consider the hierarchy to be too complex (identifying six types of centre). Three would suffice (town centre, district centre, local centre).




Therefore, recommend changes to the Policy, first that the retail hierarchy sits within its own policy. Secondly that the hierarchy is simplified to town, district and local centres. Thirdly that The Meadows is designated as a district centre.

Deloitte Real Estate for LP32 confirms that Bracknell Town Centre sits at the top of the retail Bracknell Regeneration hierarchy, which is supported. Partnership (The Lexicon) (ID871) Deloitte Real Estate for Bracknell Regeneration Partnership (The Lexicon) (ID874)

Welcome the allocation of The Lexicon, Princess Square and Bentalls Department Store site within the primary shopping area. Request that the Primary/secondary shopping frontage as shown on Map 1 of the Plan is extended to include the western elevation of unit 14 (McDonalds) and Bentalls Department Store which fronts onto the Ring. (In April 2017 BRP obtained permission to demolish and partly redevelop these units, which includes gateway enhancements to the pedestrian access from The Ring).


Considers the requirement within the Policy/supporting text para. 15.1.11 in terms of supporting evidence to be overly onerous and restrictive. Unreasonable to require an A1 unit within a primary shopping centre to potentially remain vacant for a minimum of a year, whilst making sufficient marketing evidence is collated to support an application for change of use – will have a detrimental impact on the viability of the Town Centre primary shopping area.


Request the requirement for non-A1 retail uses not to exceed 30% in primary shopping areas to be removed for the following reasons:

• Contrary to NPPF which seeks to provide flexibility in changes between use classes to support vitality and viability of town centres.

• Para. 15.1.12 does not define what would be an ‘acceptable’ change of use, nor what percentage of Bracknell Town Centres shopping area is currently in non-A1 use, or how this would be calculated.

• High Streets are changing as a result of changing consumer shopping patterns (such as increased online shopping). Government has acknowledged this change in the General Permitted Development Order 2015, which allows for more flexibility to change between use classes.

• Para. 15.1.8 confirms that flexibility within Policy LP32 , however BRP does not consider that the policy encourages the same level of flexibility to change from retail to non-retail uses.

• Policy is contrary to supporting text in relation to adapting to changing shopping behaviours (i.e. paras. 14.5.6 and 15.1.8)

Acknowledge the Council is seeking to maintain the environmental quality of Town Centres, and seeking to ensure that the offer does not negatively impact on local amenity or public health. Recommend the policy is reworded to specifically refer to a restriction on the proportion of take-away (A5) uses in the primary shopping area,




rather than applying to all other uses within Class A. This would ensure that the policy is more flexible, less restrictive and less onerous.

Welcome the support for additional residential uses within Bracknell Town Centre, agree that residential development can benefit vitality by creating activity outside of business hours/provide natural surveillance.

Responses to Policy LP33 (Advertisements and Shop Fronts)

Responses to Policy LP33 (Advertisements and Shop Fronts)




Binfield Parish Council (ID284) Agree that reasonable, unobtrusive, inoffensive advertisements should be permitted.

Binfield Parish Council (ID284) Agree that nobody wants to see a row of solid roller shutters on the evening streetscape. It’s ugly, depressing, and discourages the law abiding from frequenting such areas, due to the perceived threat that must be present to require such security.


Agree. No comment.

Historic England (ID782) Welcome and support both criteria ii. Warfield Parish Council (ID694) Supportive of policy. Would like para. 15.2.4 reviewed to include

provision for a reduction in illumination ‘out of hours’. Would result in a reduction of light pollution and save energy. Businesses/ stores/ public buildings should have a ‘turn off lights’ policy.


Policy supported.


None received.



Support the Policy.

Responses to Policy LP34 (Protection of community facilities and services)





Binfield Parish Council (ID284) Strongly agree with the need for protection of community facilities. Community facilities include parking provision for pubs and shops etc. Loss of car parking is never welcome, and can cause problems, which can never be rectified once a new house has been built. For example the ongoing parking and traffic problems caused at the Co-op, Forest Road, Binfield. The promised 12 parking spaces has become 4, causing terrible problems for residents, unnecessary risk for pedestrians and delays for road users. Double parking of delivery lorries on Forest Road and the pavement outside the Co-op has been a serious nuisance and is potentially very dangerous for pedestrians and road users.


Provision should be made for financing facilities that will support development in neighbouring areas i.e. Derby Field and Crowthorne Parish.

Warfield Parish Council (ID695) Support policy. Policy should ensure any existing provision of parking is maintained to protect local residents/ roads from parking blight.

Ministry of Defence (Defence (Infrastructure Organisation, Environment & Planning) (ID768)

Should be made clear within the document that the Policy does not apply to community facilities and services where these are ancillary to the main use of the land/buildings concerned. If any services/facilities are not longer required by the MoD it would not be appropriate to require justification of the loss of the facility (as facilities are provided on national defence requirements not public demand). Request additional wording is added to the policy/supporting text to clarify that the policy does not apply to cases where the community use is ancillary to the main use.

Sport England (ID1045) Objects to the Policy as it does not reflect Government guidance, as follows:

• Under bullet point 3, if a sports facility is proposed to be lost, it can be replaced with another sports facility – not a different type of community facility. Sports facilities are very different to churches, pubs and other community facilities.

• Paragraph 74 also does not allow applicants to demonstrate that sports facilities are surplus to requirements following a marketing period or take into account whether or not the site. Sports facilities by their nature are expensive to run and maintain. This policy could make it easier for developers to buy sites, damage the sports infrastructure on the site and claim that they are no longer needed.

The Council should also consider mentioning Assets of Community Value in this policy and provide a commitment to protecting these through the planning process.




Bracknell Town Council (ID444) Protection of community facilities and services is welcomed.


Policy supported, suggested amendment: Should include specific reference to health and wellbeing of residents to be inserted in the first paragraph “Development proposals which enhance the health and wellbeing, social and recreational facilities will be permitted where… …”


Murphy (ID637) Para. 15.3.2. Absence of community facilities and services in areas relating to allocations at LP6 and LP7, and will not change with allocations.


Hall & Woodhouse (Southern Planning Practice) (ID1213)

As the name suggests, this policy is primarily directed to the retention and protection of existing facilities, particularly in existing centres, rather than necessarily encouraging and supporting new provision in tandem with new residential provision. There is very little in the policy to set out the positive support that should be given to the provision of additional community facilities, including public houses, particularly in association with the new residential development being proposed.

Responses to Chapter 16: Historic Environment - General

Responses to Chapter 16: Historic Environment - General




Historic England (ID783) Section 16: Welcome and support.


Neill (ID1338) Support. Buildings are to be maintained as important to Bracknell’s cultural history.


None received.

Responses to Policy LP35 (Protection and Enhancement of the Historic Environment)





Binfield Parish Council (ID285) Para 16.1.1. Strongly agrees. Binfield Parish Council (ID285) Para 16.1.7. Wishes to have the words “unless it is clearly justifiable

and unavoidable” removed. Binfield Parish Council (ID285) Para 16.1.12. Agrees. Would like to see proactive intervention in the

cases of threaten loss of heritage assets through deliberate neglect and/or vandalism.

Binfield Parish Council (ID285) Agrees subject to the following. Policy point A. Amend to remove “where possible”. Heritage assets are important and should be preserved for themselves. The parish contains at least 73 listed heritage sites, with 35 buildings, walls, monuments, piers, bridge and gardens. These assets and their settings contribute positively and deserve preservation. Will strongly oppose planning applications which diminishes these assets. The recent development in and around the kitchen garden of Binfield House resulting in harm to the listed wall and the setting of Binfield House is an example of the type of development that will strongly oppose. Policy needs to be strong enough to be able to counter development proposals of this nature.


Policy is required to place properties under Conservation to give protection.

Historic England (ID784) Policy LP35: Section A of the policy should refer to the significance of heritage assets. The Heritage Statement should identify ways of avoiding or mitigating any harm to the significance of heritage assets, and the development proposals should demonstrate how they have taken the Heritage Statement into account.

Section B of the policy should include non-scheduled heritage assets of archaeological interest that are demonstrably of equivalent significance to scheduled monuments (see paragraph 139 of the NPPF). The retention, repair and re-use of designated (as well as non-designated) heritage assets should be encouraged.

Would encourage an additional specific development management policy or policies setting out the requirements of development proposals and providing a clear indication of how a decision maker should react to a development proposal affecting a heritage asset or assets as required by paragraph 154 of the NPPF. Should include criteria for assessing the potential impact of development proposals on the significance of all relevant designated heritage assets: listed buildings, Scheduled Monuments (and non-scheduled archaeological assets of archaeological interest that are demonstrably of equivalent significance to scheduled monuments), conservation areas and Registered Historic Parks and Gardens.




Need to identify those particular characteristics of each type of heritage asset that contribute to its significance and which therefore should be protected or enhanced through development proposals.

Paragraph 16.1.9: Suggest that “conserved and enhanced” would be better than “preserved and enhanced”, as terminology more consistent with the NPPF.

Paragraph 16.1.10: Confuses heritage interest and values and the definitions of non-designated heritage assets in the NPPF. Definition of “heritage interest” is contained within the definition of “significance” in the Glossary. Accordingly, a non-designated heritage assets is a building, monument etc meriting consideration in planning decisions because of its archaeological, architectural, artistic or historic interest, but which does not merit formal designation.

“Group and Townscape Value” and “Community Value” are not considerations for identifying non-designated heritage assets. They may, however, perhaps be criteria for identifying heritage assets that are of particular local interest and which therefore merit inclusion on a “local list”.

Paragraphs 16.1.12 and 16.1.13: Currently two assets at risk on the Historic England Heritage at Risk Register: the Registered Historic Parks and Gardens of Newbold College and Broadmoor Hospital, but outside London, the Register does not include secular Grade II buildings at risk.

Key evidence: Suggest adding the Historic England Heritage at Risk Register and the East Berkshire Historic Landscape Character Assessment. The National Heritage List for England, the Schedule of monuments and Register of historic parks and gardens are different and separate. The chapter on Plan-making in the NPPF is also relevant to the consideration of the historic environment in local plans.

NPPF requires local plans to be “positive”, “enhancing” and deliver”. The Plan should be proactive in the conservation and enhancement of the historic environment. Refer to National Planning Practice Guidance. Local plan must contain commitments to positive measures for the historic environment – need more explicit commitments in order to demonstrate a “positive strategy” for the conservation and enjoyment of, and a “clear strategy” for enhancing,




the historic environment.

Do not consider the Plan to demonstrate an adequate positive strategy for the conservation and enjoyment of, or clear strategy for enhancing, the historic environment as required by the NPPF - not sound in this respect.


Policy supported.



Para 16.1.10 welcomed as it recognises the importance of non-designated heritage assets. However, BFC does not maintain a list of non-designated assets. Suggested amendment to Para C: “The Council will prepare and maintain a list of non-designated heritage assets”.


Leigh (ID77) Part B, C of the Policy and para. 16.1.9 are not consistent with the NPPF. They contain a simple statement that any harm will automatically lead to a refusal of planning permission. Para. 133 of the NPPF refer to substantial harm or total loss, but consent could still be granted is there are substantial public benefits to outweigh harm or loss.

Wording is also inconsistent with para. 134 of the NPPF as it says that where there is less than substantial harm, then that harm must be weighed against the public benefits of the proposal.

Further conflicts with Part B, which requires where harm is identified for there be to be ‘sustainable opportunities to enhance and better reveal the significance and legibility of designated heritage assets’, which is not a test of para. 133 and 134 of the NPPF. Enhancing the significance and legibility of an asset may be one public benefits, but not the only feasible one. Therefore the wording unreasonable constrains public benefits to just one aspect.

Broadmoor Hospital (ID245) Point B regarding designated heritage assets should be revised to accord with paras 133 and 134 of the NPPF as the presumption against a grant of panning permission for any level of harm as currently drafted is inconsistent with the NPPF and fails to recognise that other considerations may apply. The wording under point B. should be amended to reflect the NPPF as follows: “There will be a presumption against a grant of planning permission for development proposals which cause substantial harm or total loss of significance of designated heritage assets unless other considerations outweigh the harm or loss.”





Supports the policy approach to heritage.


Section A • First para - the expectation for all development proposals to

avoid harm is overly restrictive, as is the requirement for all proposals affecting heritage assets to have sympathetic design, as this would arguably not be possible for all types of development.

Section B • ‘presumption against…proposals which would cause harm

to…designated heritage assets’. This is overly restrictive as it doesn’t allow for the scale of harm/weighing of public benefits, as is required to take place, as explained at paras 133 and 134 of the NPPF.

• The content of the second para is overly onerous. Albeit, depends in part by what the Council mean by being ‘required to seek sustainable opportunities…’.

Section C • Reference is made to non-designated heritage assets being

‘protected from harm’. This is overly restrictive, and conflicts with last sentence, which acknowledges that harm may occur. Needs to be consistent with para 135 of the NPPF on the matter, which refers to a balanced judgement being needed with regard to any harm.

• For the same reason, the suggestion that development which harms a non-designated heritage asset ‘…will not normally be permitted’ is overly restrictive and does not adhere with the approach set out at para 135 of the NPPF.

Section D • The policy advises ‘no development will be permitted…

[unless, in relevant cases] a programme of archaeological mitigation has been agreed...’ If the Council mean post-permission, pre-commencement on-site then that would be a reasonable requirement. However, if the intention is that the Council will not grant planning permission until mitigation has been agreed then that would be unnecessary and unreasonable, and should be amended accordingly

Bewley Homes (ID 1489) Section A • First para - the expectation for all development proposals to

avoid harm is overly restrictive, as is the requirement for all proposals affecting heritage assets to have sympathetic design, as this would arguably not be possible for all types of development.




Section B • ‘presumption against…proposals which would cause harm

to…designated heritage assets’. This is overly restrictive as it doesn’t allow for the scale of harm/weighing of public benefits, as is required to take place, as explained at paras 133 and 134 of the NPPF.

• The content of the second para is overly onerous. Albeit, depends in part by what the Council mean by being ‘required to seek sustainable opportunities…’.

Section C • Reference is made to non-designated heritage assets being

‘protected from harm’. This is overly restrictive, and conflicts with last sentence, which acknowledges that harm may occur. Needs to be consistent with para 135 of the NPPF on the matter, which refers to a balanced judgement being needed with regard to any harm.

• For the same reason, the suggestion that development which harms a non-designated heritage asset ‘…will not normally be permitted’ is overly restrictive and does not adhere with the approach set out at para 135 of the NPPF.

Section D • The policy advises ‘no development will be permitted…

[unless, in relevant cases] a programme of archaeological mitigation has been agreed...’ If the Council mean post-permission, pre-commencement on-site then that would be a reasonable requirement. However, if the intention is that the Council will not grant planning permission until mitigation has been agreed then that would be unnecessary and unreasonable, and should be amended accordingly

Gladman (ID1022) Notes the inclusion of the policy, and refer to it reflecting the guidance in the NPPF, para. 126-141.

Section B) – should relate paras. 133-134 of the NPPF in relation to assessing the significance of designated heritage assets.

Section C) – should reflect para. 135 of the NPPF in relation to balanced judgement should be reached having regard to the scale of any harm and the significance of the heritage asset.

Barton Willmore on behalf of Consider the policy to be inconsistent with the NPPF (paras. 133 Harrison Housing (ID1057), and 134), as it does not allow for the balancing of the level of harm Willson Developments Ltd to a designated asset’s significance against the wider public benefits (ID956), and Syngenta (ID1567) of the proposed.

There is no reference made to the consideration of scale of harm (i.e. less than substantial), nor any reference to the weighing of the level of harm against the wider public benefits.

Responses to Chapter 17: Natural Environment - General





None received.


Murphy (ID789, 638) Contradiction between para. 17.1.1 “… all Local Authorities have a statutory duty to conserve biodiversity” and what is happening in some areas of the borough. How does this meet NERC 2006 obligations?

Murphy (ID789) Bird species number and diversity area a good indicator of habitat health. In wider area around north Warfield regular survey work over a decade indicates a decline in species, including the lark. Emphasises need to retain traditional countryside to link different areas. Green areas within settlements is not a substitute for traditional countryside.

BBOWT (ID1215-1219) Several of the proposed greenfield housing site allocations include land designated as Habitat of Principal Importance under the NERC Act 2006, such as deciduous woodland and heathland. Anyproposals to develop these sites should comply with statutory and policy obligations to ensure they result in a net gain for thenature conservation value of these sites.

Proposals must also meet the mitigation hierarchy enshrined within NPPF whereby (paragraph 118) “if significant harm resulting from a development cannot be avoided (through locating on an alternative site with less harmful impacts), adequately mitigated for, or, as a last resort, compensated for, then planning permission should be refused”.

Gunn (ID1207), Fazey-Gunn (ID1243)

Sites (such as Winkfield Row) are on fields teeming with wildlife. No development should happen until a full survey has taken place, and there are full mitigation measures.


Under that information from Natural England is awaited, understanding their approach to the methodology adopted in the Plan will assist.

Concerns at this stage::

Do not consider the Habitats Regulations Assessment has fed into the process of site allocations. Sites have been allocated a then measures for mitigation of harmful effects have been put forward. Consider that habitat protection should be a major constraint when considering new sites.

In terms of Thames Basin Heaths SPA, consider that development (such as Cluster 3) will have an impact, taking account of the impact




of existing, but unbuilt commitments.

Concern also raised regarding the proximity of the Air Quality Management Area in Crowthorne to Cluster 3.

In the north of the Borough, the Windsor SAC is likely to be affected by road usage and air pollution, increased by additional homes in Winkfield/Hayley Green.

Protection should be considered at a first priority, approach appears to be allocate then mitigate.


None received.

Responses to Policy LP36 (Biodiversity)





Natural England (ID118) Advises that wording for point iii) is changed to: ‘Wherever possible…’ instead of ‘Where appropriate…’ to reflect the Borough’s stance on biodiversity net gain.

Binfield Parish Council (ID286) Point i to be replaced with: “Development proposals will be expected to: i. Comprehensive and wide-ranging information taken from relevant ecological survey(s) should be forthcoming to establish the extent of a potential impact where there are grounds to believe that ancient woodland, veteran trees, inland freshwaters (42), protected species, priority species or priority habitat may be affected during and after development. This information shall be provided prior to the determination of an application.”

Binfield Parish Council (ID286) Have some concerns with the mitigation hierarchy. It seems that developers will only have to say they cannot avoid or mitigate in order to be able to compensate for their development. The policy should be amended to state that compensation is an absolute last resort when contemplating development and that development would normally be refused in these circumstances.

Binfield Parish Council (ID286) Para 17.1.11. The development of a standard method for calculating biodiversity losses and gains and identifying the level of compensation required (known as a Biodiversity Accounting Metric) should be a priority developed alongside the local plan and be adopted prior to the adoption of the local plan.


No comment.

Warfield Parish Council (ID697) Generally supportive. Consider 17.1.4 should be merged with 17.1.3; makes no sense on its own.


Policy supported.


Murphy (ID638) Supports references to achieving no net loss and wherever possible net gain in biodiversity, but question how this achieved in practice, such as rural allocations (e.g. LP7), where greenfield/agricultural will be developed.

Murphy (ID638) Para. 17.1.7. Wildlife corridors, does this include residential gardens? Historic OS maps show where old establish habitats persist today, which could inform choices for where to preserve/enhance habitats and GI/ecological networks.

Murphy (ID638) Para. 17.1.11. How does this meet NERC 2006 obligations? Murphy (ID638) Para. 17.1.12. This para. suggests this is an optional extra. What is

meant by “enhancement measures should be delivered to support ecological networks where possible.”, doesn’t align with LP36.

Wallen (ID838), Warfield Paras. 17.1.10, 17.1.11, a developer can always find a way to mitigate




Environment Group (ID1197) to allow to build, this provides a get out clause. Wallen (ID838), , Warfield Environment Group (ID1197)

In the mitigation hierarchy, what is meant by ‘compensation’. Money is not a substitute for habitat loss.

Collings (ID1089, 1081) How can the loss of a veteran tree, ever be compensated for? It may have taken hundreds of years to grow.

BBOWT (ID1215-1219) Further clarification is required and it lacks adequate content:

1 Achieving net gain in biodiversity

LP36 reads: “Development in the Borough should achieve no net loss and wherever possible a net gain of biodiversity.”

The delivery of the Borough Local Plan must result in a net gain in biodiversity. To achieve this all developments must deliver a net gain in biodiversity where possible.

This is an unambiguous requirement of the NPPF (paragraphs 9, 109, 118 and 152) and more broadly (paragraphs 7, 17, 114, and 157), including reference to enhancing biodiversity. Refer also to NPPF planning guidance (https://www.gov.uk/guidance/natural-environment#biodiversity-and-ecosystems)

Section 40 of the Natural Environment and Rural Communities Act 2006, which places a duty on all public authorities in England and Wales to have regard, in the exercise of their functions, to the purpose of conserving biodiversity. A key purpose of this duty is to embed consideration of biodiversity as an integral part of policy and decision making throughout the public sector, which should be seeking to make a significant contribution to the achievement of the commitments made by government in its Biodiversity 2020 strategy…

The National Planning Policy Framework is clear that pursuing sustainable development includes moving from a net loss of biodiversity to achieving net gains for nature, and that a core principle for planning is that it should contribute to conserving and enhancing the natural environment and reducing pollution.” [our underlining for emphasis]

BBOWT recommendation NPPF and NERC Act 2006 compliant wording: “Development in the Borough will be expected to achieve a measurable net gain ofbiodiversity.” (alteration to existing text is underlined).

BBOWT (ID1215-1219) 2 Demonstrate achieving net gain in biodiversity using a quantitative metric Policy LP36 currently lacks any requirement for development proposals to quantify their biodiversity net gain.

Requiring all developments to quantitatively assess theirbiodiversity impact through the use of a biodiversity metric based on the DEFRA guidance is the most appropriate and




simplest way the Borough can demonstrate that net gains are being delivered. The Defra Biodiversity Offsetting guidance (DEFRA 2012) provides as established method.

We note the statement in paragraph 17.1.11 that the Council is considering developing a Biodiversity Accounting Metric, but in the absence of any requirement in policy LP36 for applicants to demonstrate quantitatively that a net biodiversity gain will be achieved when a planning application is submitted, the Council cannot be assured that new developments will actually comply with NPPF requirements to deliver a net biodiversity gain.

BBOWT Recommendation (As 1 above)

BBOWT (ID1215-1219) 3 Biodiversity in built development Point (iii) of policy LP36 states “Where appropriate, enhance biodiversity by designing-in provisions for wildlife”.

This policy wording, and the wording of supporting text in paragraph 17.1.8 is not sufficient to ensure that new developments integrate biodiversity features wherever possible and appropriate to do so. Whilst we acknowledge and welcome the proposed policy LP38 on Green Infrastructure, which deals with strategic multi-functional green space planning, there needs to be a Borough Local Plan steer towards taking all available opportunities to incorporate biodiversity features (such as integrated bird and bat roosts, bug hotels, green walls and roofs, climbing plants and fruiting trees [table provided in response]) into buildings and built developments.

There is a clear requirement in the NPPF (paragraph 118) for planning authorities to encourage opportunities to incorporate biodiversity in and around developments. Multi-functional benefits are possible.

BBOWT Recommendation Policy LP36: “Wherever possible, design-in provisions for wildlifeto maximise opportunities for biodiversity”. (alteration to existing text is underlined).

Supporting text of paragraph 17.1.8: “When considering a site fordevelopment, those involved should consider what biodiversityresources there might be on the site and design the development in a way that avoids, or minimises, any negative impacts on these resources. Opportunities to enhance biodiversity on the site, such as creating new habitats, should be incorporated into the design. Creative solutions are possible on all sites, including small sites within urban areas. Examples of what would be expected are set out below.” (alteration to existing text is underlined).

A table is provided for use in the supporting text.




BBOWT (ID1215-1219) 4 Irreplaceable habitats The draft plan lacks any reference to irreplaceable habitats. Irreplaceable habitats include, but are not limited to, ancient woodland and veteran trees.

The NPPF states in paragraph 118 that “planning permission should be refused for development resulting in the loss or deterioration of irreplaceable habitats, including ancient woodland and the loss of aged or veteran trees found outside ancient woodland, unless the need for, and benefits of the development in that location clearly outweigh the loss;”.

The most appropriate location for policy wording that reflects the requirement of the NPPF regarding irreplaceable habitats is likely to be Policy LP36 but may also require reference within Policy LP37 and any new policy specifically dealing with trees, woodland and hedgerows.

BBOWT Recommendation To be compliant with the NPPF, Policy LP36 should include: “Development proposals that would lead to individual or cumulative significant harmful effects on irreplaceable habitatwill be refused unless wholly exceptional circumstances can bedemonstrated in which the harm to the habitat is clearly outweighed by the benefits of the development.” (proposed text is underlined).

BBOWT (ID1215-1219) 5 No definition of “ecological features” Policy LP36 point (ii) and the third main paragraph of Policy LP36 refer to “ecological features” but these are not explicitly defined within the policy (although there is a non-exhaustive list in policy point (i) of what are some ecological features), or the supporting text.

BBOWT Recommendation Amend Policy LP36 point (i): “Provide an adequate level of suitableecological survey information and assessment to establish the extent of a potential impact where there are grounds to believe that ecological features such as ancient woodland, veteran trees,inland freshwaters(42), protected species, priority species or priority habitat may be affected during and afterdevelopment[…]”. (alteration to existing text is underlined).

BBOWT (ID1215-1219) 6 Timescales for aftercare, monitoring and management The plan does not specify any timeframe over which biodiversity enhancements must be maintained, managed and monitored.

Any habitat to be protected and/or managed for nature conservation as part of protected species mitigation or intentionto secure net gain in biodiversity must be sustained over the longest possible timeframe (i.e. in perpetuity) to ensure a genuine net gain legacy. In practice this means sites should be secured for at least the lifetime of the Local Plan with dedicated




management and monitoring planned to continue beyond this timeframe. This is recommended as good practice for development by the Chartered Institute of Ecology and Environmental Management (CIEEM et al, 2016) and is the timeframe of the avoidance strategy for the Bracknell Forest Thames Basin Heaths SPA.

There is no broadly agreed definition of perpetuity in relation to planning, but the NPPF states in paragraph 58 that “Planning policies and decisions should aim to ensure that developments will function well and add to the overall quality of the area, not just for the short term but over the lifetime of the development”.

BBOWT Recommendation To be compliant with the NPPF and best practice standards, Policy LP36 should include: “Mitigation, compensation and enhancementmeasures must be secured and maintained in perpetuity”. (proposed text is underlined).

In other districts, guidance on this policy provision states that management of such measures should initially be secured over 30 years post-completion, allowing the applicant time during this period to make further arrangements to secure management and monitoring of the sites into perpetuity. An example roadmap of how this can be achieved can be seen on p11 of the Buckinghamshire Natural Environment Partnership (equivalent to the LNP) green infrastructure strategy (http://www.bucksmknep.co.uk/wp-content/uploads/2016/09/NEP-GI-Vision-and-Principles-FINAL.pdf). It may be appropriate to include supporting text in this respect in the Local Plan.

BBOWT (ID1215-1219) 7 Objective The stated objective for Policy LP36 is to “Protect / enhance existing assets”. This fails to mention the creation of new biodiversity assets (i.e. habitat creation), which is one of the key environmental objectives of the NPPF.

The NPPF clearly states in paragraph 114 that “Local planning authorities should: ● set out a strategic approach in their Local Plans, planning positively for the creation, protection, enhancement and management of networks of biodiversity and green infrastructure;”

BBOWT Recommendation NPPF compliant wording for the Objective would be “Protect /enhance existing assets and creation of new assets” (additional proposed text is underlined).

(Comment duplicated in Section 3, Plan Objectives) BBOWT (ID1215-1219) MISSING POLICY - TREES, WOODLANDS, HEDGEROWS

The Borough Local Plan appears to lack any specific policy regarding the protection and enhancement of trees, woodlands, hedgerows and




other wooded habitats such as traditional orchards. We consider this an oversight given the clear biodiversity, carbon storage, pollution control, aesthetic and amenity value ofthese habitats and the particular practical and legislative requirements for their protection and conservation.

Native hedgerows, deciduous woodland, traditional orchard and veteran trees are priority habitats under the NERC Act 2006 and also variously protected under specific legislation such as the Forestry Act 1967 (as amended), Town and Country Planning (tree preservation) (England) Regulations 2012 and the Hedgerow Regulations 1997 and statutory guidance such as Natural England and Forestry Commission Standing Advice on ancient woodland and veteran trees (https://www.gov.uk/guidance/ancient-woodland-and-veteran-trees-protection-surveys-licences). We are of the opinion that the complex landscape of legislation and statutory guidance pertaining to these features requires a dedicated policy within the Borough Local Plan.

In addition, paragraph 117 of the NPPF states; “To minimise impacts on biodiversity and geodiversity, planning policies should: ●plan for biodiversity at a landscape-scale across local authority boundaries; ●identify and map components of the local ecological networks, including the hierarchy of international, national and locally designated sites of importance for biodiversity, wildlife corridors and stepping stones that connect them and areas identified by local partnerships for habitat restoration or creation; ●promote the preservation, restoration and re-creation of priority habitats, ecological networks and the protection and recovery of priority species populations, linked to national and local targets, and identify suitable indicators for monitoring biodiversity in the plan;” Deciduous woodland, traditional orchards and hedgerows are priority habitats, which form part ofa wider ecological network within the Borough and beyond its boundaries.

Paragraph 118 of the NPPF states; “planning permission should be refused for development resulting in the loss or deterioration of irreplaceable habitats, including ancient woodland and the loss of aged or veteran trees found outside ancient woodland, unless the need for, and benefits of, the development in that location clearly outweigh the loss;”

Natural England’s Climate Change Adaptation Manual (2014) recommends there be buffer zones retained around woodland and hedgerows, increased protection for veteran trees, and additional tree and hedge planting to improve the size, diversity and connectivity between woodlands.

BBOWT Recommendation We consider that a policy on trees, woodlands and hedgerows containing clear criteria for protection and appropriate protective

https://www.gov.uk/guidance/ancient-woodland-and-veteran-trees




buffering of trees, woodlands and hedgerows is necessary for the Borough Local Plan to be compliant with the NPPF and for it to be in alignment with the various legislation and statutory guidance relating to these features. For examples of policies within our geographic region, please consider referring to the Aylesbury Vale submission draft plan https://www.aylesburyvaledc.gov.uk/valp-proposed-submission or Royal Borough of Windsor and Maidenhead submission draft plan https://www3.rbwm.gov.uk/info/201026/borough_local_plan/1351/sub mission/1.

RSPB (ID1226) Supportive of policy. Suggest that all developments should secure net gain for biodiversity.


Broadmoor Hospital (ID246) Point ii. should be amended to reflect the relative value of ecological features and NPPF paragraphs 109 and 117.This paragraph should be reworded as follows: “Minimise impacts on biodiversity and promote the preservation, restoration and enhancement of priority habitats (including inland freshwaters), ecological networks and priority species.”

Gladman (ID1021) Highlight the need of for the policy to reflect para. 109 of the NPPF.

Do not consider that the hierarchy approach outlined in para. 118(1) of the NPPF is reflected in the proposed policy wording.


Consider it would be difficult to clearly demonstrate when intentional removal or degradation of “biodiversity” has taken place, particularly if through neglect, which should not be akin to the absence of active management. Also consider it would be difficult to demonstrate what the biodiversity value of a site would have been prior to any removal or degradation. Therefore seek the deletion of the following paragraph of the policy:

“Where the biodiversity has been intentionally removed or degraded (including through neglect), the Council will view biodiversity value to be as it would likely to have been had the removal or degradation not have occurred.”


Support the Policy with eth following suggested amendments to paras, 2, 3, 6 & 7:

“Development proposals will be expected to, where appropriate:”

“Development proposals on or affecting ecological features, non-designated sites or wildlife corridors (including river corridors) will only be supported where it can be demonstrated that the need for the development outweighs any harm caused by the development and that adequate mitigation measures are put in place can be implemented.”




“Where the biodiversity has been intentionally removed or degraded (including through neglect), the Council will view biodiversity value to be as it would likely to have been had the removal or degradation not have occurred.

The Council will secure effective avoidance, mitigation and compensation through the imposition of planning conditions or planning obligations as appropriate, including monitoring for the effectiveness of these measures.”

Responses to Policy LP37 (Designated Nature Conservation and Geological Sites)





Natural England (ID118) Recommend that the best and most versatile agricultural land (BMV) is added to this section. Further information can be found in Natural England’s Technical Information Note 049.

Binfield Parish Council (ID286) Agrees with the policy. Crowthorne Parish Council (ID420)

No comment.


Policy partially supported. Para.i) not supported. Cannot conceive of any overriding public need that would have sufficient weight to merit development in designated areas.


Murphy (ID638) How can sites be allocated in the BFLP, whilst none have been screened out by the draft HRA? HRA should be a key factor in deciding site allocations.

BBOWT (ID1215-1219) The first paragraph of this policy omits reference to internationally designated sites.

In addition, policy points (i) and (ii) place incorrect emphasis on supporting development that affects internationally and nationally designated sites. There should be a clear presumption against development that adversely affects internationally and nationally sites, as intended by the NPPF.

Development likely to have a significant effect on a SAC or SPA requires appropriate assessment under the Habitats Regulations 2017. The NPPF is clear that the presumption in favour of sustainable development (paragraph 14) does not apply in such instances.

Note that all SACs and SPAs should also already be designated as SSSIs. In relation to SSSIs, the NPPF states in paragraph 118 that “proposed development on land within or outside a Site of Special Scientific Interest likely to have an adverse effect on a Site of Special Scientific Interest (either individually or in combination with other developments) should not normally be permitted. Where an adverse effect on the site’s notified special interest features is likely, an exception should only be made where the benefits of the development, at this site, clearly outweigh both the impacts that it is likely to have on the features of the site that make it of special scientific interest and any broader impacts on the national network of Sites of Special Scientific Interest;”




Policy point (iii) places an incorrectly broad emphasis on supporting development that affects locally designated sites. Development proposals that may adversely affect locally designated sites should be considered on a case by case basis, incorporating information about the site, its significance for nature conservation and the scale and relative significance of thedevelopment being proposed, and any mitigation.

Local nature sites (LWS and LNRs) often encompass priority habitats and/or protected and priority species and can be of equivalent quality to SSSIs. Their integrity is a material consideration in the planning process and the Council has a legal duty under the NERC Act 2006 to have regard to the purpose of conserving biodiversity, with specific responsibility (Planning Practice Guidance) to “make a significant contribution to the achievement of the commitments made by government in its Biodiversity 2020 strategy”. The NPPF further iterates this in paragraph 117: “To minimise impacts on biodiversity and geodiversity, planning policies should: promote the preservation, restoration and re-creation of priority habitats, ecological networks and the protection and recovery of priority species populations, linked to national and local targets, and identify suitable indicators for monitoring biodiversity in the plan;”

BBOWT Recommendation Policy LP37 (first paragraph) should be amended to comply with the NPPF: “Any planning application affecting designated nature conservation and geological sites must ensure that these sitesare safeguarded and enhanced having regard to theinternational, national or local status and designation of the site as set out below”. (additional proposed text is underlined).

Policy LP37 point (i) should be amended to comply with the NPPF: “i. Development proposals on or affecting internationallydesignated sites (SPAs and SACs), including candidate sites, will be refused unless it can be clearly demonstrated that thereis an overriding public need or it can be demonstrated that there will be no significant adverse effect on the integrity ofthese sites.” (additional proposed text is underlined; redundant text is crossed out).

Policy LP37 point (ii) should be amended to comply with the NPPF: “ii. Development proposals on or affecting nationally designated sites (SSSIs), will be refused unless exceptionalcircumstances can be demonstrated and that where the benefits of the development clearly outweigh harm to the natureconservation value of the site.” (additional proposed text is underlined).

Policy LP37 point (iii) should be amended to comply with the NPPF: “iii. Development proposals on or affecting locally designated sites (LNR, LWS, LGS) will be considered on a case by case




basis and may only be supported where it can be demonstrated that the need for the development outweighs the harm to the nature conservation value or geological value of the site.” (additional proposed text is underlined). The addition of further supporting text may also be appropriate.


Broadmoor Hospital (ID246) Point i. does not reflect the legal tests of the Habitats Directive. The wording should be amended to reflect the correct interpretation and legal test. Suggested wording as follows: “Development proposals on or affecting internationally designated sites (SPAs and SACs) will be supported where it can be demonstrated that there will be no likely significant adverse effect on the integrity of these sites or as otherwise acceptable in accordance with the legal tests of the Habitats Directive.”

Gladman (ID1020) Note the criteria based approach proposed. Important that the approach reflects section 11 of the NPPF. In particular making a clear distinction between the hierarchy of international, national and locally designated sites, so that protection is commensurate with their status and gives appropriate weight to their importance and the contribution that they make to wider ecological networks.


Support the Policy.

Responses to Policy LP38 (Green Infrastructure)





Natural England (ID119) Advise that wording is added to the Policy to ensure the protection and enhancement of Public Rights of Ways.

Brett (ID 220, 221) Insufficient evidence. Binfield Parish Council (ID287) Broadly agrees with the policy. Attention is drawn to the comment

about compensation in policy LP36, which also applies. Binfield Parish Council (ID287) Agrees that, where possible, green infrastructure should be

connected for example in London it is possible to walk through Hyde Park to Victoria without passing any built environment. This is so important for the quality of life enjoyed by Bracknell residents and should be encouraged even if this has to be done through developers in the local plan.


No comment.

Environment Agency (ID1267) Generally support policy with particular reference to paragraph 17.2.5, referring to blue infrastructure.

However, strongly recommend policy includes requirement for a 10m undeveloped area alongside main rivers, ensuring policy meets requirements of Objective B to protect natural assets and developers know required standards. Increased importance for inclusion as SFRA identifies that majority of flooding within Borough is along river corridors and emphasises protecting this with a 10m buffer. Revisions would ensure plan is consistent with evidence base and Policy LP40.

Strongly recommend revisions made to include opportunities for de-culverting of watercourses to be actively pursued. Suggested wording: ”Planning permission will only be granted for proposals which do not involve the culverting of watercourses and which do not prejudice future opportunities for de-culverting”.

Downhill Stream watercourse has been heavily damaged and almost entirely lost through culverting when Bracknell rapidly expanded.

Environment Agency (ID1267) Support Green Infrastructure definition in paragraph 17.2.5, including reference to flood zones, waterbodies and riparian corridors.

Warfield Parish Council (ID698) Generally supportive of policy. Consider in para. 17.2.1 the issue of how green infrastructure can be better ‘connected’ needs greater emphasis within policy. Little or no reference as to how to enhance PRoW and permitted path network can help link green sites. Para. 17.2.5 should include significance of enhancement to the PRoW network. Para. 17.2.10 PRoW network appears to be ignored in chapter.


Policy supported.





Murphy (ID789) Pleased to see allotments mentioned as an option as one form of green space. Used to be common feature of villages in Warfield. Not included in Warfield Neighbourhood Plan.

Murphy (ID640) What isn’t Green Belt included in the remit, which is surely the largely GI in north Bracknell?

Murphy (ID640) Bullet list within the Policy (and para 17.2.7) is comprised by including concept plans and new settlement boundaries for new allocations, before adequate GI and related biodiversity evidence is available.

Murphy (ID640) Scarcity of GI landscape and visual amenity assets in Warfield is further threatened by development plans – allocating elsewhere could help improve the lack of grassland GI.

Wallen (ID839) Para. 17.2.7. Multi-functional can cause conflicts, e.g. larks will not breed in areas where dogs are present.

Collings (ID1082, 1089), Warfield Environmental Group (ID1198)

Para 17.2.4 (p151) As well as contributing to human well-being, green infrastructure should also contribute to the well-being of our wildlife. In Warfield, the aptly-named Larks Hill has lost its skylarks (UK conservation status red – the highest conservation status, with the species needing urgent action) and it looks likely that the same will happen on Cabbage Hill. In the provision of green infrastructure, especially SANG, why does all of the land have to be accessible to humans (and particularly their dogs which are the greatest risk to wildlife)? Cannot some of it be kept truly wild and inaccessible?

(Also summarised in relation to Countryside and SPA policies)


Gladman (ID1019) Notes the intention of the policy. Any requirement for provision of natural green space should be commensurate with the need arising from the proposal, having regard to the quality and quantity of existing provision in the area.


Support the Policy.

Responses to Policy LP39 (Thames Basin Heaths Special Protection Area)





Binfield Parish Council (ID289) Despite being materially affected by the policy, recognises the importance of the Thames Basin Heath Special Protection Area and has no comment to make.


No comment.


Policy supported.



Para 17.3.8 (p157) SANG should be provided to protect the Thames Basin Heaths, but not at the expense of other endangered wildlife. In Warfield, the aptly-named Larks Hill has lost its skylarks (UK conservation status red – the highest conservation status, with the species needing urgent action) and it looks likely that the same will happen on Cabbage Hill because of human access and especially their dogs. Please leave some inaccessible land for our wildlife.

(Also summarised in relation to Countryside and Green Infrastructure policies)

RSPB (ID1227) Advise amendments to the policy as follows:

Zones of Influence - “ i. A straight line distance of between 0 and up to 400 metres from the SPA boundary.” “ii. … Within this zone measures must be provided for all residential proposals for 1 or more net new dwelling units to ensure that the integrity of the SPA is protected…”

SANG Standards - “v. Large developments as defined in supporting guidance may be expected to provide bespoke SANG, that should accord with Natural England’s SANG guidelines and can includes a combination of benefits such as biodiversity enhancement, green infrastructure and, potentially, new recreational facilities…”

SAMM Contributions – “Per dwelling Developer contributions will be made toward the Strategic Access Management and Monitoring (SAMM) Project.

Amend Para 17.3.4 to appropriately reference Article 4 of the EU Birds Directive (Council Directive 2009/147/EC) and this Directive is transposed into UK law by the Conservation of Habitats and Species Regulations 2017 (the Habitats Regulations).





Tingdene Developments Ltd (ID376), Bracknell Land Ltd (ID396)

Footnote 7 of the draft sustainability appraisal states that the draft Habitats Regulations Assessment has identified potential air quality effects from all residential developments identified in Policy LP3 on the integrity of the Thames Basin Heaths SPA and the Windsor Forest and Great Park SAC, but likelihood yet to be determined. Note that the Council is working with Natural England to development a methodology for an air quality assessment, to be carried out at the submission stage. The air quality assessment is part of the evidence base under pinning the plan, and should therefore take place prior to submission of the plan for examination.

(also summarised under evidence base: Sustainability Appraisal) Broadmoor Hospital (ID246) Comments made on the Draft Thames Basin Heaths SPA SPD

should be taken into account. Broadmoor Hospital (ID246) Should be amended to correctly reflect the legal tests of the Habitats

Directive, which allows approval of development where it can be demonstrated there is no likely significant adverse effect on the integrity of the SPA, or where further legal tests of the Habitats Directive can be met.

Avoidance and mitigation measures must be taken into account in when considering likely significant effects. In order to meet the legal tests of the Habitats Directive it is not necessary to mitigate “any potential adverse effects” but mitigation of likely significant effects’; so development is acceptable. Where adequate mitigation measures cannot be offered then a plan or project must be assessed against the legal tests set out in articles 6(3) and 6 (4) of the Habitats Directive. Any plan or project which meets these tests may be granted planning permission.

Broadmoor Hospital (ID246) Point i. is inconsistent with the full wording of Policy NRM6 with regard to development within 400m from the SPA boundary and proposes a more rigid interpretation and approach.

Policy NRM 6 recognises that developments within 400m of the SPA will be assessed on their own merits and exceptional circumstances may apply where mitigation is capable of protecting the integrity of the SPA. The wording of point i. should be amended to reflect this by recognising that proposals “will not be supported unless it can be demonstrated that there will be no likely significant adverse effect on the integrity of the SPA or where the legal tests of the Habitats Directive are not met.”

Broadmoor Hospital (ID246) The requirement for provision of bespoke SANG as a minimum of 8ha per 1000 new occupants is consistent with Natural England guidelines on SANGs and was established as the correct standard by the technical assessor to the South East Plan. There is no variation in the application of the standard across the 400m - 5km zone of influence which would suggest that in excess of this




standard is required according to the type and size of the development or proximity of development to the SPA. The same minimum standard applies in all instances unless as defined by Policy NRM6 “Where further evidence demonstrates that the integrity of the SPA can be protected using different linear thresholds or with alternative mitigation measures (including standards of SANG provision different to those set out in this policy) these must be agreed with Natural England”. The last sentence of point v. should be deleted as it is inconsistent with the requirements of Policy NRM6 and fails to recognise the application of the SANG standard applied regardless of scale and proximity and provides no clear basis for applicants to bring forward applications with the confidence that the SANG requirements are known and agreed.

Gladman (ID1018) It is important that a positive strategy is put in place for the enhancement and protection of environmental assets of this nature and that this is considered within the Council’s viability evidence.

Boyer on behalf of Jordan Consider it is unclear why “other small sites in areas outside of the Construction (ID1367) defined settlement boundary may have to provide or contribute

towards a bespoke SANG solution”, if they were otherwise acceptable in planning policy terms would not qualify for Council-owned strategic SANG. In recent years, when the Council has had a 5 year housing land supply shortfall for instance, small developments outside the existing defined settlement areas have been found acceptable based on presumption in favour of sustainable development in the NPPF. Should such a shortfall occur again, the wording of LP39 may prevent such sites coming forward. Recommend sentence is deleted from policy.


Agree with the content of the Policy. The Council should ensure that it is able to provide sufficient SANG capacity for small-scale residential development which are unlikely to be capable of providing SANG on-site or securing alternative provision from third parties.


Support the Policy.

Responses to Chapter 18: Climate Change and Environmental Sustainability - General

Responses to Chapter 18: Climate Change and Environmental Sustainability - General




Binfield Parish Council (ID291) Support planning conditions requiring permeable solutions for driveways and paved areas wherever possible.

Environment Agency (ID1268) Chapter Objectives should be expanded to include Objective B as areas of natural floodplain are a valued natural asset which should be protected.


Brown (ID87) Section 18.1 is limited in coverage of climate change as restricted to flooding and drainage and does not include adapting to increased risks from heat drought, importance of green infrastructure, nor acknowledge the potential future risk from wildfire. Reference made to the Committee on Climate Change and the CCC 2017 progress report: which found that local planning policies and building regulations are not delivering resilience to higher temperatures and extreme rainfall.


Para. 18.3.14, should also include reference to other water courses.

Murphy (ID641) Para. 18.1.1. Is allocating and drawing settlement boundaries contrary to where a Level 2 SFRA is indicated (40% of allocated sites).


Removal of fields and addition of hard standing will add to problems (reference made to Winkfield Row flooding on a regular basis).


None received.

Responses to Policy LP40 (Flood Risk)






No comment.

Environment Agency (ID1268) Whilst there is nothing fundamentally wrong with Policy, it is not locally specific reflecting the SFRA, contrary to the SA (paragraph 3.87). Policy reflects national policy. Recommend amend policy reflecting the SFRA, highlighting that majority of Borough is in Flood Zone 1. Development in areas of flood risk should only be supported where there is identified need through application of Sequential Test and Exception Test.

SFRA identifies areas of groundwater flooding which should be covered in policy requirements.

Recommend flood risk standards are set out, which could include sequential approach (built development located in lowest risk area of site), specifying height of finished floor levels, standards of flood mitigation in the form of flood compensation and requiring development in flood risk areas to provide an increase in flood storage.

Policy should identify that development will not be supported in Flood Zone 3b (defined by SFRA) or more recent modelling.

Policy does not adequately reflect need to address impact of climate change, highlighted in paragraphs 18.1.1 and 18.1.2.

Environment Agency (ID1268) Supporting text should promote early discussions with EA at pre-application stage, to address flooding issues for sites within flood risk areas.

Warfield Parish Council (ID700) Generally supportive of policy. Warfield Parish Council (ID700) Would like BFC to require householders to install permeable

driveways and paved areas wherever possible. Thames Water Utilities Limited (ID731)

Support Section 18.1, Policy LP40 and paragraphs 18.1.1 and 18.1.2, specifically referencing all types of flood risk including pluvial, as requested in Issues & Options response.


Policy supported.


Murphy (ID641) First bullet list iii). This should rule out drawing settlement boundaries for sites that have failed SFRA Level 1.

Murphy (ID641) How is flood risk and potential for mitigation balanced with other site constraints such as landscape and biodiversity? (Some sites have all three such as Cluster 3, how is this addressed, including siting of SuDS?)




Murphy (ID641) Para. 18.1.3. A failed SFRA should not allow settlement boundaries to be defined within sites, and information not complete. What is meant by “The Council will expect…”. Could imply the site-specific assessment only at planning application stage, which is too late to inform settlement boundaries.

Murphy (ID641) Para. 18.1.6. How far did the SFRA level 1 inform site allocations. Wallen (ID840), Warfield Environment Group (ID1200)

Policy needs to include reference to controlling paving over front gardens, as this increases surface run-off.


None received.

Responses to Policy LP41 (Sustainable Drainage Systems)





Binfield Parish Council (ID291) Fully supportive of the need to address flooding concerns, both on developed sites, and consequential effects downstream. Strongly support the proposed SuDs requirements.


No comment.

Environment Agency (ID1268) Recommend policy in paragraph 18.1.16 highlights the benefits of green roofs with regard to biodiversity mitigation for new developments.

Environment Agency (ID1268) Recommend all new developments should use SuDS and not just those in areas prone to flooding – see Policy LP41 (i).

Warfield Parish Council (ID700) Recognise importance of SuDS, especially in para. 18.1.19 that the borough must be satisfied SuDS are designed with regard to long-term maintenance costs, and in para. 18.1.20 requiring SuDS to replicate natural drainage where possible, and bring other benefits (amenity, recreation, wildlife).


Support paragraphs 18.1.16 – 18.1.18, Policy LP41. Support SuDS in new development based on the positive impact - help to mitigate flooding by controlling surface water but also improve water quality, water efficiency opportunities, provide enhanced landscape/ visual features, support wildlife, provide amenity/recreational benefits.

TWUL will work with BFC and EA to ensure SuDS opportunities are maximised, effectively adopted and maintained over their lifetime.


Should be reference to what happens when flooding occurs during the development of a site. Suggested amendment to policy: “In the event of flooding occurring during the build phase of a site all development of the site will cease until full and acceptable remedial action is taken and any compensation, where applicable, agreed.”


Brown (ID87) Good to see the inclusion of a specific SuDS policy, but more emphasis should be placed on a presumption towards green SUDs as opposed to grey SuDS such as underground tanks.


Barton Willmore on behalf of Willson Developments Ltd (ID 961)

Support the Policy.


Support the Policy with amendments to first para, i) and ii):

“Development will only be permitted if all the following criteria are met, where appropriate:”

“ii. Major development proposals (defined below) shall




incorporate SuDS unless it can be demonstrated that provision on site is inappropriate or unviable;

iii Where appropriate development proposals shall include SuDS as an intrinsic part of the design and layout, withoutcreating excessive maintenance burdens to futureowners/occupiers;”

Responses to Policy LP42 (Addressing Climate Change through Renewable Energy and Sustainable Construction)





Binfield Parish Council (ID291) Fully supportive of the need to address climate change, and fully support the proposed requirements.

Binfield Parish Council (ID291) Would also like to see positive measures introduced to encourage the fitting of solar panels, and use of ground source heat pumps etc.

Binfield Parish Council (ID291) Could some measures also be introduced to encourage the orientation / positioning of housing so that solar panels can operate efficiently?


No comment.

Warfield Parish Council (ID701) Fully supportive of policy and standards laid out to address climate change. Would expect to see percentage of new homes using renewables.


Policy partially supported. Proposed changes to Policy CS12 reduce the need for renewables, which is regarded as a backwards step. It does not minimise the use of fossil fuels and natural resources as outlined in LP1. Development should include at least 20% on-site renewable energy to all buildings, not just domestic.


All proposed development must incorporate best environmental practices for energy economies.


Murphy (ID642) Strategic transport principles can only help meet climate objectives, if developments can comply with LP45.


Para 18.2.11. Shame that renewable energy sources are not routinely installed into all new builds. Surely it is easier and cheaper to install them during development than retrospectively?


Boyer on behalf of Shanly Homes (ID1349); Boyer on behalf of Jordan Construction (ID1368)

Support in principle, but as currently drafted Policy is vague and ineffective. There is no guidance on what an acceptable ‘proportion’ is considered to be.

Boyer for Bloor Homes Limited (ID928)

Essential that robust justification is provided as to why the water efficiency levels should be improved beyond Building Regulations.

Gladman (ID1017) The proposed standards within the Local Plan should be thoroughly considered and tested through the proportionate evidence base, including any assessment of viability. The wording of the policy should reflect the wording of the NPPF (para. 17). To support the move to a low carbon future, LPAs should carefully consider and reflect the Government’s approach to the setting of optional technical standards for new housing within local policies.




Persimmon Homes North This policy requires development proposals to meet climate change London (ID1410) objectives through, interalia, achieving water efficiency standards of

110 litres/person/day, which goes beyond the requirement of 125 litres/person/day as stipulated by Building Regulations. This should only be applied when sufficient evidence can be provided to demonstrate that these enhanced standards are needed and viable.

The Policy is supported by the Bracknell Forest Water Cycle Study Phase 1 Scoping Report (2017), which confirms providers have sufficiently planned future water resources to respond to predicted population growth in accordance with figures provided by the DCLG and no supply issues have been identified. In addition, it is confirmed that neither water company has relied on new homes being more water-efficient than existing metered homes, and that the overall assessment for Bracknell Forest’s water resources is green. Therefore, the evidence put forward by the Council does not demonstrate there is a need for enhanced water efficiency standards and confirms there are no predicted issues with water resources based on current population projections when applying the mandatory standards set out in Building Regulations; and does not justify the application of the enhanced standards.


Reference made to para. 56-002 of the PPG in relation to LPAs having the option to set additional technical requirements exceeding the minimum standards required by Building Regulations, and evidence being required to determine whether there is a need and justify policy approach. In light of this, consider reference to BREEAM should be removed, as the new optional standard do not require developments to meet such standards.

Also consider the wording of criterion ii should be revised to allow an element of flexibility, as follows:

ii. Residential development shall meet water efficiency standards of 110 litres/person/day, or in accordance with any subsequent updates to the standards.


Support the Policy subject to amendment of first paragraph:

“New development proposals (excluding extensions) will be required to meet climate change objectives and achieve a high standard of environmental sustainability. This will be achieved, where appropriate, possible and viable, by the following:”

Responses to Policy LP43 (Pollution and Hazards)





Natural England (ID120) It should be acknowledged that noise and water pollution can also impact upon biodiversity and designated sites, such as SSSIs/SPAs/SACs (depending upon their site specific vulnerabilities). Further assessments will be required as necessary to assess these impacts and to inform mitigation where appropriate.


Noise and air quality caused by increased traffic needs to be taken into account in the infrastructure requirements (see para 18.3.23). Crowthorne High Street is already over the guidance threshold.

Environment Agency (ID1269) Support policy. Warfield Parish Council (ID702) Support policy but consider it could go further on light pollution in

countryside. Would welcome need for a lighting assessment with applications.

Sport England (ID1046) Object as concerned that the policy and supporting text could result in it becoming more difficult to provide lighting or facilities. There is reference to lighting affecting biodiversity and each site will need to be assessed on its merits. It would be helpful if the areas of ecologically sensitive areas for the purposes of the policy were identified. Sport England has further advice on flood lighting which could be referenced in the Policy: https://www.sportengland.org/facilities-planning/design-and-cost-guidance/artificial-sports-facilities/

Paragraph 18.3.19 - concerned that this paragraph will make it more difficult to extend the hours of sports facilities or build new ones. Where new residential development is proposed adjacent to existing outdoor sports facilities this matter also requires careful consideration. Sport England has the following guidance note on addressing acoustic issues relevant to artificial pitches: http://www.sportengland.org/facilities-planning/design-and-cost-guidance/artificial-sports-surfaces/

Sandhurst Town Council Policy supported. Pleased to see strong emphasis on light pollution (ID1135) and noise/vibration. The policy needs to make more reference to

transport infrastructure and traffic queues, as engines running are a contributor to poor air quality.



In general welcome section 18, including paras 18.3.3, 18.3.24 and reference to individual/cumulative impact to human health and safety within Policy LP43. However, wish to see this obligation of the planning process to avoid contributing additional pollution in relation where there is already an AQMA (for example Crowthorne High Street). Also draw attention to the ‘Wealden District Council v.

https://www.sportengland.org/facilities-planning/design-and-cost-guidance/artificial-sports-facilities/

https://www.sportengland.org/facilities-planning/design-and-cost-guidance/artificial-sports-facilities/

http://www.sportengland.org/facilities-planning/design-and-cost-guidance/artificial-sports-surfaces/

http://www.sportengland.org/facilities-planning/design-and-cost-guidance/artificial-sports-surfaces/




Secretary of State for Communities and Local Government, Lewes District Council and South Downs National Park Authority [2017] EWHC 351 (Admin)’ judgement, where Lewes Core Strategy was overturned as the cumulative effect of new developments (including those in adjoining boroughs) were not correctly assessed in relation to sensitive habitats. Suggested amend, additional wording: “In order to maintain compliance with national legislation on air quality, there should be a presumption against granting of permission for any new development which would add additional traffic to an existing AQMA until the exceedance in the AQMA has been demonstrated to have been rectified.”

Murphy (ID643) Para. 18.3.2, 18.3.5. Noting the intention to avoid cumulative impact, will this feed into the HRA to include unbuilt SA allocations as well as new BFLP allocations to 2034?

Murphy (ID643) Para. 18.3.9. This should ensure inadequate infrastructure in Hayley Green and Winkfield (Policies LP6/LP7) is upgraded.

Murphy (ID643) Para. 18.3.12. Bright (supported by sufficient street lighting) environments are not necessarily safer. They also provide lighting for criminals.

Murphy (ID643) Para. 18.3.14. Could a specific ‘dark skies’ policy be created to ensure Green Belt and countryside, and settlements within them do not acquire increased levels of artificial light.

Murphy (ID643) Paras. 18.3.23 and 18.3.24. Has the AQMA in Crowthorne and N-deposition status of the SPA been taken into account in allocating LP4?

Murphy (ID643) Para. 18.3.27. Unbuilt SA allocations do not appear to be have been screened against Windsor SAC. In combination assessment of all BFC projects/plans to 2034 and other authority need to be undertaken.

Murphy (ID643) Para. 18.3.31 – how are the identified failings regarding the WFD being addressed?


Para 18.3.25 (p174) Whilst efforts to reduce our reliance on cars are to be applauded, difficult to achieve in practice.


Gladman (ID1016) The supporting text at 18.3.3 indicates the policy has two aims. It is considered that these aims are accurately reflected in the policy wording, together with taking account of the requirements of national policy (para. 109 of the NPPF).

Responses to Policy LP44 (Development of Land Potentially affected by contamination)

Responses to Policy LP44 (Development of Land Potentially affected by contamination)




Binfield Parish Council (ID291) Agree that planning applications could be supported but only with strict controls to ensure appropriate removal and avoidance of wider spread of contaminants. However, have strong reservations about this policy. There needs to be very strict controls to ensure proper decontamination and to prevent the wider spread of contaminants. Pro-active overseeing by Borough Council officers with regular site visits is expensive and time-consuming. Questions whether the Borough has the resources to ensure that contaminants are removed prior to development. Who would be responsible if there were problems twenty, thirty or more years after a development were completed?

Binfield Parish Council (ID291) Particular concerns about the extent of research and analysis of the former refuse site at Amen Corner South.


No comment.

Environment Agency (ID1524) Support policy. Pleased to see paragraph 18.4.11 addresses issue of infiltration drainage through contaminated land by stating SuDS should be carefully designed to protect water bodies.

Warfield Parish Council (ID703) Support policy. Sandhurst Town Council (ID1606)

Policy supported.


Jennings (ID1174, 1183) Development of contaminated land should be encouraged as it can be a rare example of development improving the local environment.


None received.

Responses to Chapter 19: Transport. General

Responses to Chapter 19: Transport. General




None received.


Murphy (ID646) Seems unachievable for development outside of the town. Can BFC point to a large development that has not contributed to congestion/pollution?


Bus stops few and far between (such as Winkfield Row – significant investment will be needed to support additional homes).


None received.

Responses to Policy LP45 (Strategic Transport Principles)






Whilst public transport is good along the Thames Valley, it is poor across the Thames Valley. Travel times to Windsor, Maidenhead, Slough, Camberley and Guildford by public transport do not encourage its use. Travelling to High Wycombe by public transport is unusable due to travel time in excess of three hours.

Binfield Parish Council (ID292) Para 19.1.1. Strongly agree. Binfield Parish Council (ID292) Agrees in the main. Wish to make comments regarding points v and

vii. Binfield Parish Council (ID292) Point v. How does the Borough interpret the word ‘appropriate’ with

regard to parking? Residents of smaller properties come off worse for parking availability and there is not enough visitors’ parking. Sufficient, not just adequate, parking spaces should be provided from the outset of any new development and developers need to ensure the ‘street scene’ is not detrimentally affected (not just around tall buildings (see L19)).

Developers must always provide at least the minimum required by the parking standards. Perhaps, the Borough can look again at these standards and improve, at least, the number of visitor spaces provided on every development not just those around flats and tall buildings.

Many estate roads are narrow and parking on the street can cause problems to residents and visitors. Emergency vehicles will also need to have unencumbered access to properties.

Binfield Parish Council (ID292) Point vi. It is appalling that Bracknell Forest tops the list of the ten hardest hit areas in England with more than 25% of its bus journeys lost in the last four years (BBC article released on 16th 2018 – attached graph). The Borough Council can change this with positive policies to promote the bus network e.g. with Section 106 contributions

Binfield Parish Council (ID292) Many developers seek to mitigate the impact of their development on the road network only at the entrance to new housing estates. There doesn’t seem to be any “joined up thinking” with regard to the cumulative impact of one or more developments in the same area. The Borough needs to think strategically about how to improve the road network in these cases, specifically about the impact on roads such as Foxley Lane, Tilehurst Lane and Murrell Hill Lane, if all the development proposed for these areas comes to fruition. These narrow country lanes were not built to take the volumes of traffic they currently experience and which may well increase further in the future.

Binfield Parish Council (ID292) Para 19.1.8. Strongly agrees that the current cycle and footpath provision be safeguarded. Would like to see further improvements to the cycle network especially in Binfield, which does not have




dedicated cycle routes in much of the parish. Crowthorne Parish Council (ID422)

See comments regarding transport in other sections.

Warfield Parish Council (ID704) Supportive of policies and principles. Sandhurst Town Council (ID1138)

Para. 19.1.2. regard should be had to the impact upon areas surrounding transport infrastructure improvements. Special care given to preventing negative effectives on the safety and amenity of local residents.


Policy partially supported.

iv) policy should be seeking to eliminate, not manage congestion.

v) LPA’s parking policies not strong enough, and need reference to “some flexibility” specified. Suggested amendment: “Provide an appropriate level of parking that complies with the approved parking standards”.

x) whilst access for waste/recycling vehicles is supported, there is no specific reference to ensuring access for emergency vehicles.


There is no reference to working with neighbouring authorities to support Policy LP45. Concern raised regarding the extent of joint working with Surrey CC and Hampshire over the Meadows roundabout.


Para. 19.1.5. No specific mention made to the extent, type, appropriateness of alternative transport options, which should also support the vulnerable, frail and elderly communities. Regard should be had to safety. Cycle paths should allow pedestrians safe travel, but be fit for purpose for commuters and sports enthusiasts.


Para. 19.1.8. Should include reference to paths being maintained in sufficient a manner not to put the health and safety of users at risk.


Murphy (ID644) Para. 19.1.5 – but C. 28,000 extra residents from SALP/BFLP with few new services / facilities (except schools) have been planned. Increase pressure on what exists, leading to traveling further afield.

Murphy (ID644) Para. 19.1.6 resulting in putting pressure on narrow, rural mainly B-road network north east of Bracknell. Planned enhancements limited in scale given scale of increased traffic to be expected.

Murphy (ID644) LP45 (ix) implications for owners of properties fronting relevant roads unclear. Proposed routes including how settlements / allocations are to be joined to each and existing network should be consulted on prior to BFLP being finalised.

Murphy (ID644) Crossrail links may draw more commuter traffic from north Bracknell via Windsor Forest and Great Park SAC leading to congestion and associated pollution. Implications at junctions/ relevant roads.

Murphy (ID644) Inadequate parking at Martins Heron station; parking in front of homes and ‘station runs’ double journey numbers (congestion/ pollution). (Para. 19.1.7).

Murphy (ID644) SW Trains should be consulted about improvements such as




increased better cycle parking at stations / routes to them; cycles on trains at peak hours. Discourages sustainable commuting without these.

Murphy (ID644) Para. 19.1.8 but IDP indicates lack of master planning / firm commitments to deliver new pedestrian / cycle routes for locations not on network.

Murphy (ID644) Shared cycle/ pedestrian routes should not deter pedestrians including elderly, children, disabled, those with sensory disabilities.

Jennings (ID1174, 1184) LP45 should be amended such that the traffic department's recent obsession with traffic lights is reversed. Journey times to and from work have increased by 10-20% in recent years due to endless red lights. This increases fuel consumption and CO2 emissions. Bring back the roundabouts.


Boyer on behalf of Shanly Homes (ID1350)

Policy requires development to provide parking, but does not set out what standards will be required, and appears to be relying on the adopted Parking Standards SPD (2016). As the parking standards will impact on the form and viability of development, they should not be established outside of the Plan. This principle was established in William Davis Ltd & Ors v Charnwood Borough Council [2017] EWHC 3006 (Admin) (23 November 2017) where a SPD strayed into an area that should be considered by a development plan document. The High Court decision quashed an SPD that contained policies that clearly encouraged and imposed development management policies against which a planning application for development could be refused. By setting standards outside of the Local Plan they cannot be interrogated or challenged at examination. Consider that if the Council wishes to adopt parking standards, these are set out in the Local Plan to ensure a full and proper examination of their impacts, in the context of paragraph 39 of the NPPF and the Written Ministerial Statement (25 March 2015).


If the Councils wishes to adopt the Nationally Described Space Standards (NDSS) , in line with para. 56-020 of the PPG, this should be justified.

Need: The Council should provide a local assessment evidence the specific case which justifies inclusion of the NDSS within the Plan, and should only be introduced on a ‘need to have’ not ‘nice to have’ basis. At present there is no evidence as to the need to introduce the NDSS.

Viability: impact of viability of this policy must be considered as part of the assessment of cumulative impact of all policy burdens. Whilst the viability study mentions space standards, it is not clear how they informed the assessment. The requirement for NDSS would reduce site yields, and less efficient use of land. A more in depth assessment of impact sis required.

Gladman (ID1015): LP45(viii) sets a principle to ‘”improve highways safety through effective design”. In order to better reflect national policy and guidance, it is considered that this should be amended to: “identify




any safety implications of development and, where applicable, identify how they will be improved”.

LP45(ix) makes reference to safeguarded routes. Further details of any safeguarded routes will need to be provided in association with is proposed requirement.

The Policy fully aligns with LP46 relating to the assessment of the transport impacts of development, LP47 on Transport Infrastructure provision and LP48 regarding Travel Plans.

Persimmon Homes North Object to the policy. This policy together with LP49 include a London (ID1411) requirement for an appropriate level of parking, however, the

required standards are not stipulated in the policy, nor is reference provided to adopted standalone standards. Standards should be included to ensure the policy is effective and positively prepared.

The wording does not allow for flexibility in the application of standards to respond to the site and local context and sustainability of the site and car ownership data etc.


Support policy.

Responses to Policy LP46 (Assessing, Minimising and Mitigating the Transport Impacts of Development)

Responses to Policy LP46 (Assessing, Minimising and Mitigating the Transport Impacts of Development)




Binfield Parish Council (ID293) Believes there needs to be quantifiable standards included in the policy and should be defining the intentions outlined in LP45: Strategic Transport Principles. As it stands, the policy doesn’t seem to provide much guidance for developers or, indeed for anyone, to identify how to minimise and mitigate the transport impacts of development.

Binfield Parish Council (ID293) Para 19.2.2. Mentions that “the transport Assessment should be supported by traffic modelling (where appropriate) using a validated model which complies with Department of Transport criteria”. The Borough Council should be providing a detailed traffic model for use with every application that requires it.

Binfield Parish Council (ID293) There is another fundamental problem in speculative developments and planned developments. Without local shops, every pint of milk, every loaf of bread, every newspaper, pack of cigarettes or box of eggs requires a journey, and residents can afford to use their car. The only way to reduce transport impacts is to ensure that new development is located in a sustainable location and has local facilities. Everything else is a waste of time and money trying to mitigate for this fundamental shortcoming.



Warfield Parish Council (ID705) Supportive of policy.


Wallen (ID841) Raises doubts regarding modelling. Whatever model used, people will use cars as main form of transport especially in village/hamlet areas. Does not consider providing more public transport will get people out of cars.

Collings (ID1086, 1089) Para 19.2.2 Why were appropriate Transport Assessments and traffic modelling not completed before BFC agreed to the development of 3,216 new dwellings in addition to the 11,139 new dwellings currently being developed? How does BFC know that the proposed new sites will not cause the road network, even with improvements, to become gridlocked?


None received.

Responses to Policy LP47 (Transport Infrastructure Provision)





Binfield Parish Council (ID294) Provision of some or all of these transport facilities will be great if they can be provided through the planning process and CIL/Section 106 agreements (links to comment on paragraph 6.2, point 3). The CIL/Section 106 pot is of a limited size to provide both infrastructure and affordable housing. Each development that comes forward needs to be specific in the improvements demanded of it. Developers need to be very clear what is being asked of them and should be asked to prove that they can deliver what they promise at the planning stage.

Binfield Parish Council (ID294) Para 19.3.4. Strongly supports the intentions. Public rights of way should be available to everyone.



Warfield Parish Council (ID706) Generally supportive, however provision x is not considered strong enough. This should require new development to provide a level of parking that meets BFC parking standards. Strongly support protection, enhancement and maintenance of PRoW.

Bracknell Town Council (ID445) Provision needs to be adequate for new sites, such as improve and strengthen links with existing communities. A range of transport modes should be catered for in addition to cars - public transport; cyclists; pedestrians. Extra transport demand created by outlying sites, should not compromise access to and from Bracknell.



Current parking at Martins Heron railway station is inadequate. With additional housing proposed, this needs to be addressed as a priority.


Government has set a target to halt the production of petrol cars by 2040, yet there is little reference to provision of electric vehicle charging points. Suggested amendment to policy, additional wording to point x: x. Provide an appropriate level of parking…”and electric vehicle charging points”.

Murphy (ID647) In IDP LP47 (i) (ii) and (iii) indicated as possible or could include. Unclear if these are being provided ad hoc or by masterplanning.

Murphy (ID647) LP47 (iv). Respondent questions if there is a masterplan following discussions with SW Trains. Site basis unlikely to effectively deliver. Refers to Martin’s Heron Station with little parking, leading to road parking outside residents homes.

Murphy (ID647) Para. 19.3.2 ambiguous/ inconsistent with BFLP policies. Use of ‘or’ indicates financial contribution will be accepted if adverse impact cannot be mitigated. Questions if unmitigated adverse impact could be acceptable, so no alternative travel options provided and associated congestion/ pollution increases (contrary to aims of policy).




Wallen (ID842) Point iv). There is not enough parking at Martin’s Heron station. More people in Winkfield and Warfield are more likely to use this station (not Bracknell).

Point v). There is not a taxi rank at Martin’s Heron.

Put a car park at the Bog Lane site for use by commuters.


None received.

Responses to Policy LP48 (Travel Plans)

Responses to Policy LP48 (Travel Plans)






Warfield Parish Council (ID707) Generally supportive of policy.


Collings (ID1087, 1089) Para 19.4.1 (p186) … reduce the overall need for car travel … Common sense and experience dictate that this is unlikely to happen.



Whilst recognise the benefits of travel plans to support sustainable development, also recognise that travel plans are not appropriate in all cases. Therefore the following amendment is suggested:

“… For residential development, where a Transport Assessment identifies that there is likely to be significant transport impacts, as an alternative to providing and implementing Travel Plans, developers may contribute a financial sum per dwelling to allow the Council to implement Travel Plan initiatives for the site and surrounding area.”

Gladman (ID1014): In line with para. 36 of the NPPF, the policy should relate to "generates significant amounts of movement" rather than " development that is likely to have significant transport impacts".

Responses to Policy LP49 (Parking)





Binfield Parish Council (ID295) Would like to see additional parking for visitors in all new development including the provision for off-street parking in housing estates.



Warfield Parish Council (ID707) Do not consider that any relaxation of current parking standards should be permitted. All development should meet BFC parking standards to prevent parking becoming uncontrollable.


None received.


Boyer on behalf of Shanly Homes (ID1350), Jordan Construction (ID1369), W J Channing & Sons (Woking) Ltd (ID1386), House Builders Federation (ID1271)

Policy does not set out standards, it appears to rely on the adopted Parking Standards SPD. Parking standards will impact upon the form and viability of development, and should not be established outside of the Plan. This matter was considered through William Davis Ltd & Ors v Charnwood Borough Council [2017] EWHC 3006 (Admin) (23 November 2017) where a SPD strayed into an area that should be considered by a development plan document. The High Court decision quashed an SPD that contained policies that clearly encouraged and imposed development management policies against which a planning application for development could be refused.

(Shanly Homes, Jordan Construction & W J Channing and Sons reps also include reference to para 39 of the NPPF and Written Ministerial Statement 25 March 2015. Conclude that therefore, if the Council wishes to adopt parking standards, these should be set out in the Local Plan to ensure a full and proper examination of impacts).

Persimmon Homes North Object to the policy. This policy together with LP45 include a London (ID1411) requirement for an appropriate level of parking, however, the

required standards are not stipulated in the policy, nor is reference provided to adopted standalone standards. Standards should be included to ensure the policy is effective and positively prepared.

The wording does not allow for flexibility in the application of standards to respond to the site and local context and sustainability of the site and car ownership data etc.

Barton Willmore on behalf of Reference made to Inspector’s questions on the Vale of Aylesbury Harrison Housing (ID1051) Local Plan , therefore suggest the policy is updated to set its own

parking standards without relying on other supporting documents:

"Standard PINS advice is that a supplementary planning document (SPD) does not have statutory force and is not the subject of




examination.. Consequently policies should not simply devolve fundamental matters to SPD although they may legitimately add further detail to policies or provide guidance as per the definition in the NPPF. Policies that require compliance with an SPD on matters such as car parking are unlikely to be consistent with national policy"


Agree with draft policy, subject to amendment to criteria i):

Provides vehicle, cycle and other parking (including parking for people with disabilities) and electric vehicular charging facilities in accordance with current standards, or in accordance with anv subsequent updates to the standards.

Responses to Chapter 20: Local Infrastructure and Facilities - General

Responses to Chapter 20: Local Infrastructure and Facilities - General




Bracknell Town Council (ID431, 432, 433)

Opportunities should be taken to work with the NHS and health providers to bring forward additional facilities (provision of health infrastructure is a frequently voiced concern of residents).


Para. 20.1.3. Should public golf courses be included as an example.


Para. 20.1.5. The paragraph should be in line with objectives to protect and enhance existing assets. Does saying ‘mitigate’ mean general amenities could be degraded?


Winkfield does not have a GP surgery. None of the sites (Whitmoor Forest, Winkfield Row and Hayley Green) include any provision for health facilities. This is unacceptable and must be addressed and made a condition of any planning permission.


Tuffley (ID993) No comments to make. Murphy (ID648) Para. 20.1.4. What built sports provision is being made for north

Bracknell, where there is no sports centre, public swimming pool, but additional housing planned to 2034.

Collings (ID1088, 1089), Warfield Environment Group (ID1203)

Para 20.1.8 (p190) Please leave some space just for wildlife.

Collings (ID1088, 1089), Warfield Environment Group (ID1203)

20.1.17 (p192) Please leave some space just for wildlife.


None received.

Responses to Policy LP50 (Play, Open Space and Sports Provision)





Binfield Parish Council (ID296) Agrees with the policy. Binfield Parish Council (ID296) Would like to see Binfield parish connected fully to the footpath and

cycle network if that is possible. Crowthorne Parish Council (ID423)

Policy required where facilities are provided by neighbouring towns and parishes to fund their expansion and running costs.

Warfield Parish Council (ID708) Supportive of policy. Hope BFC will work with towns and parishes to ensure provision meets needs.

Sport England (ID1040) Supports the intention of the Policy, but have some concerns:

• criteria (i) – do not support the use of standards. Sports facilities are a very different type of open space (with regards to demand for, cost and the required maintenance), in comparison to the other types of open space included within this policy.

• Para. 20.1.7. Concerned that the current policy is insufficient to protect playing fields and other sports facilities and this should be given further consideration by the Council.

• Supports the view on the dual use of sites, in particular the extended use of school sites for the benefit of the community. Sport England has developed a toolkit regarding accessing schools for community use which may be of use, available via the below link: http://www.sportengland.org/Useourschools

Bracknell Town Council (ID431, 432, 433)

Section is welcomed, as provision of these facilities is a major part of Bracknell Town Council’s activities.


Policy supported.


Para. 20.1.14. Supported only if measures are taken to validate and ensure that the changed function will serve at least the same or greater requirements.


Para. 20.1.17. Impact of noise and traffic should not be to the detriment of amenities of local residents.


Wallen (ID843) Para. 20.1.18. Typo ‘monitoring’. Wallen (ID843) Where will the football club go if the site is being built on? DEVELOPERS/PROMOTERS OF SITES

Gladman (ID1013) Requirements of the Policy noted. Such requirements will need to be justified through evidence base.

The policy should recognise that there may be circumstances where existing open space, sports and recreational buildings and land,

http://www.sportengland.org/Useourschools




including playing fields ,ay be redeveloped for an alternative use.

The NPPF (para. 73) recognises the importance of access to high quality open spaces, and opportunities for sport and recreation to the health and well-being. It is therefore vital that robust evidence is provided and maintained.

Whilst the NPPF (para. 73) recognises the importance of open space, it also enables its redevelopment for alternative uses.


Agree it is important for play, open space and sporting provision to be protected, and where possible enhanced. However, consider that draft Policy LP50 and LP51 should be merged to create one policy. LP50 on its own gives the impression that all development must provide for any play, open space and sporting needs it creates, yet LP51 states that residential development can provide financial contribution in lieu of on-site OSPV provision.

Responses to Policy LP51 (Standards for Open Space of Public Value)





Binfield Parish Council (ID297) Agrees with the policy. Binfield Parish Council (ID297) Concerned about provision of land for sports use, both organised

and casual. While often made available for organised sports, school playing fields are completely inaccessible for casual play during weekends and holidays. Need somewhere for kids to go.


Policy required where facilities are provided by neighbouring towns and parishes to fund their expansion and running costs.

Warfield Parish Council (ID709) Supportive of policy. Sport England (ID1041) Object to the Policy, does not support the use of standards for open

space and facilities.

Do not support the use of the Fields in Trust standard as this is a nationally set standard and may not be appropriate for Bracknell.

The Council has undertaken a Playing Pitch Strategy and the actions arising from this work, should be delivered through the Council’s development plan policies and Infrastructure Delivery Plan.


Policy supported.


Murphy (ID649) Table 10. Column 4 only refers to woodland, where as Column 1 is broader (natural, semi natural). Column 6 same comment.



Policy does not provide enough clarity on when on-site open space will be required, and when an off-site contribution will be acceptable. Policy states this will be agreed on a case by case basis. Accept that on larger sites there will be need for a degree of negotiation, but for smaller developments, the Council should indicate the size at which sites will be required to provide on-site provision.

Persimmon Homes North London (ID1412)

Whilst agree that it is logical for the amount of open space provided to be commensurate with the scale of the development, there is no evidence why this scale of provision (4.3ha per 1,000 population) is proposed. Current position is unjustified, and evidence should be provided to demonstrate that the provision would meet current and future needs for open space.

Table 8 – there is no justification for the triggers and variations in the size of open space provided either by on-site or financial contribution.

The policy confirms that the amount of on and off-site provision is derived from previous standards of 30% on-site and 70% financial




contributions in lieu of provision. There is no detail provided as to when this was development. This needs to be re-evaluated against up to date evidence.

The policy should allow for flexibility in the form of provision of open space to allow for greater on-site provision or off-site contributions based on site specific circumstances.

Quality standards – The Plus One Principle. Acknowledged within the Policy that this standard was first developed in 2006. Do not consider this is an up to method for assessing the standard and quality of open space.

In addition, the Policy does not include the criteria and guidelines of the Plus One Principle which will be used to assess the quality of open space.

The Policy requires new open space to be provided to an ‘excellent’ standard, however no evidence to justify the application of this standard. This includes a built in assumption that all existing open spaces are already of this quality – there is no mechanism to collect contributions towards the enhancement of existing spaces.

There is no consideration of the additional financial burden that will be placed on developers as a result of the need to provide contributions which have not been previously allowed for. The policy does not include a standard formula for calculating this resulting in uncertainty in assessing viability of development.

OSPV accessibility standards. Table 10 provides a summary of the different forms of open space and recommended travel distances. There is no evidence of why these distances are considered appropriate.


Agree it is important for play, open space and sporting provision to be protected, and where possible enhanced. However, consider that draft Policy LP50 and LP51 should be merged to create one policy. LP50 on its own gives the impression that all development must provide for any play, open space and sporting needs it creates, yet LP51 states that residential development can provide financial contribution in lieu of on-site OSPV provision.

Responses to Appendix 1: Policy LP2 – Housing Trajectory

Responses to Appendix 1:

Policy LP2 – Housing Trajectory




Binfield Parish Council (ID298) Policy LP2. Encouraged by the data and are hopeful that the figures will allow the council to actively plan development around Bracknell, and not be at the mercy of speculative and aggressive planning applications outside agreed development areas.


No comment.

Warfield Parish Council (ID710) Whilst evidence base comprehensive, consider should be cautious about proposed housing trajectory based upon experience of delivery of the Warfield SALP.


Grand total of land supply shows an average rate of 710 dwellings per annum, which greatly exceeds the OAN. This demonstrates unwelcome development is not required within the plan period, and should be resisted.

Unclear how developers will be made to deliver the required trajectory.


None received.


See comments on specific sites.

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Responses to Appendix 1: Policy LP3 and LP8 – Site Allocations Overview Maps

Policy LP3 and LP8 – Site Allocations Overview Maps




Binfield Parish Council (ID298) No comment or changes. Crowthorne Parish Council (ID424)

Figure 7 unclear settlement boundaries.


Figure 8, 11 to 18 no comment.


Figure 9 see comment 11.2 (ID403).


Figure 8 Derby Field shown as change in settlement boundaries as this area is adjacent to Crowthorne Parish who will be providing the majority of facilities to the development because it is distanced from Sandhurst facilities. Is it therefore also suggested that the Crowthorne Parish boundaries are also changed.

Warfield Parish Council (ID711) Concerned about spread of schools proposed in site allocations; feel many speculative rather than achievable. Consider further work should be undertaken to ensure proposed school sites meet needs of local communities and are put where demand required. No supporting evidence about why these sites were chosen as location for schools.


SAND 5. Table 17 (map 19) states one of the requirements is to comply with a adopted policies of the development plan. Given the significant weight to securing settlement boundaries and preventing coalescence of settlement of Sandhurst and Crowthorne, this site cannot be progressed.


Map 8 – Jealott’s Hill. There can be no acceptance of any development outside the boundary shown. The proposed land to be added to the developed site carries no justification for or very special circumstances as to why such expansion should be acceptable. Sandhurst Town Council repeats its commitment to supporting the strongest possible defence of the Green Belt and associated Green Belt policies and calls for any addition to the developed site be rejected.


The additions and removals outlined in maps 9, 10, and 11 are supported.


Map 22 Sandhurst (West of Swan Lane) The map boundary of the retail centre should be extended to include the Nightingale Dental Surgery located at 7 York Way as it provides essential healthcare facilities.


Wallen (ID844) Figure 11. Maps should show houses already development at Cabbage Hill and Amen Corner.


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Responses to Appendix 1: Policy LP3 and LP8 – Site Allocations Overview Maps




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Responses to Appendix 1: Site Profiles for sites listed in Policy LP3

Site Profiles for sites listed in Policy LP3 (excluding sites within the Bracknell Town Centre* and sites covered by policies LP8), Policy LP17, Policy LP27, Policy LP32

(Also see comments on specific sites)




Binfield Parish Council (ID298) Bin1. No reference to the curtilage of the grade II* listed building, and other grade II listed heritage assets in the near vicinity. The quoted dph of 30 seems high for a rural location outside the settlement boundary.

Binfield Parish Council (ID298) Bin5. Requirements should consider the effect of the proposed development on Forest Road, pupil’s pedestrian access to the school at Blue Mountain and the drop-off area off Wood Lane. Residents are strongly opposed to this development.

Binfield Parish Council (ID298) Bin6. No mention about the means of access, and mitigating effects on existing residents. Residents are very strongly opposed to this development.

Binfield Parish Council (ID298) Bin11. Disappointed that there is no reference to the curtilage of the grade 2 listed buildings, and gate piers in the near vicinity. Given that outline permission has been granted, wishes to see access through Amen Corner North development, not via Murrell Hill Lane.

Binfield Parish Council (ID298) Bin7. Concerned about the effect of development on problematic traffic on Foxley Lane. The land is known to be vulnerable to flooding.

Binfield Parish Council (ID298) Bin10. If development does go ahead, wish to see access through Amen Corner North development, not via Murrell Hill Lane.

Binfield Parish Council (ID298) Bin12. Access to this site must not be directly onto London Road. Crowthorne Parish Council (ID424)

Table 17, Figure 19. Derby Field shown as change in settlement boundaries as this area is adjacent to Crowthorne Parish who will be providing the majority of facilities to the development because of its distance from Sandhurst facilities. Suggested that Crowthorne Parish Boundaries are also changed with the CIL going to Crowthorne Parish.


Figure 20 to 27 no comment.

Binfield Parish Council (ID298) Policy LP27. Supports the proposals. Binfield Parish Council (ID298) Policy LP32. Happy to see some protection for the retail centres, and

strongly support these proposals. Warfield Parish Council (ID712) No comment on sites profiles for LP3. Warfield Parish Council (ID712, 1539)

Notes change proposed to return land from the development site to the Green Belt.


No comment on LP27 employment areas maps.


No comment on LP32 defined retail centres maps.

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Comments in relation to Cluster 3 (page 210, Fig 9). See also comments on Policy LP4. Map is not up to date as it does not show development at Oakham Park, so is misleading in terms of residual gap between Crowthorne Village and proposed Cluster 3. Amendments: update map or amend plan so exits are to Great Holland Ring Road, or amend settlement boundary so it is an extension of Crowthorne and CIL goes to Crowthorne. (Also see comments on LP4).


Comments relate to Derby Field. Fig 19 and Table 17, page 226. Development of the site represents an opportunity to remedy insufficient parking at Crowthorne station, and lack of public transport connection from the station to Crowthorne Village. It would also be good to have an off-road turning space where buses can turn and load without impeding traffic on Dukes Ride – these should be included in the Plan.

It is noted that this site would require an extension to the settlement boundary. Currently this field is within Sandhurst Parish. Since residents will be accessing facilities in Crowthorne Village, there should be an extension of Crowthorne Parish boundary to encompass this new development.

(Also see comments on SAND5)


Boyer on behalf of Luff Developments (ID1328)

Suggest that draft Table 12 is amended to include reference to “suggested capacity”.to accord with draft Policy LP3 and will provide flexibility.

Under the requirements section of the table, it is suggested that the following amendments are made:

• Provision of up to 14 affordable homes

The provision of affordable housing is based upon a percentage of the overall development proposed. It is important that the Site Profiles reflect the flexibility of draft Policy LP3. The affordable housing listed here will therefore need to include flexibility.

The Map of Bin5 at draft Figure 14 shows the revised settlement boundary with a significant buffer to the south of the site. There is existing planting along this boundary. However, this is the boundary with the golf course on Land West of Wood Lane, which will be retained as an intensified golf use (planning permission ref. 17/00031/REM). Due to the highly managed nature of the golf course it is not of high ecological value. The proposed amendment to the settlement boundary is considered to provide an unnecessarily large buffer. Our initial ecological and arboricultural assessments

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have not demonstrated a need for this. In order to make best and most efficient use of land, Luff suggest that the settlement boundary is revised to reduce the buffer area and allow a slightly larger developable area within Bin5

Suggest that draft Table 13 is amended to include reference to “suggested capacity”. Under the requirements section of the table it is suggested that the following amendments are made:

• Provision of up to 12 affordable homes

Draft Figure 15 shows the indicative developable boundary being significantly set back from the boundary with Emmets Park. It is unclear why the developable area should be set back here. Initial assessments have been undertaken and do not demonstrate a need to set the development back. Indeed it will be important for any development within Bin6 to address the existing development of Emmets Park and to respond to the existing character, grain and built form.

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Responses to Appendix 2 Existing Policies to be Replaced by the Bracknell Forest Local Plan

Responses to Appendix 2 Existing Policies to be Replaced by the Bracknell ForestLocal Plan




Crowthorne Parish Council (ID425), Warfield Parish Council (ID1542)

No comment.

Ministry of Defence (Defence (Infrastructure Organisation, Environment & Planning) (ID766)

Support the retention of Policy SA10 (Royal Military Academy, Sandhurst) as part of the Development Plan for Bracknell Forest.


Needs to be an assurance statement that says the wording of the new policy has not diminished the weight or significance of the former (replaced) policy. Assurance required as the older policies have been tested and found to be strong, where as the emerging policies have not been tested,

For example, old Green Belt Policy GB4 includes (iv) which states “The proposed change of use or adaption would not be detrimental to the character of the building, its surroundings and landscape setting:”. The new policy LP16 does not give any weight to the character of a building and whether it fits in with its surrounding and setting, which is considered to be weaker.


Woolf Bond on Behalf of Warfield Park (ID1281)

(Also see comments on omission sites and LP11).

Object to the replacement of saved policy EN11 with LP11 – see comments on LP11.

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Responses to Appendix 3 Glossary and Abbreviations

Responses to Appendix 3 Glossary and Abbreviations




Crowthorne Parish Council (ID426), Warfield Parish Council (ID1543)

No comment.


Noted.

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Responses to the overall Plan (not section specific) and other matters/comments/proposed changes to the Draft Bracknell Forest Local Plan

Responses to the overall Plan (not section specific) and othermatters/comments/proposed changes to the Draft Bracknell Forest Local Plan




South East Water (ID4) Further to previous comments, additional analysis has been undertaken, in conjunction with South East Waters next business plan. As a guide to supply the developments, it is likely required to lay new mains in Carters Hill and also in London Road, Popeswood roundabout and Wokingham Road bringing more water into Bracknell from our Buckhurst Reservoir on the west of the town.

Ministry of Defence (Defence (Infrastructure Organisation, Safeguarding Department) (ID162)

The statutory explosive safeguarding zone for Sandhurst Royal Military Academy is situated within the Borough of Bracknell Forest. There are two zones: the Inhabited Building Distance (IBD) and the Vulnerable Building Distance (VBD). Policies Map has been reviewed and identifies (Map 4: Sandhurst and Crowthorne) a proposed for development (Policy SA10). Although part of the area falls outside of statutory safeguarding zones, east and north eastern part of the site falls within the VBD safeguarding zone surrounding the Sandhurst Royal Military Academy. In principle no safeguarding objections to proposed developments in the safeguarding zone, note requests to be consulted on future planning applications within the area so more detailed safeguarding assessments can be completed.

Binfield Parish Council (ID743) It has taken 2 hours to copy and paste the comments, review them and then submit. There is no global submit function, no function to delete comments which are duplicates. Members of the public would refuse to use and instead email in comments.

Surrey County Council

(ID1394)

Welcome the fact that minerals and waste matters are being pursued via a Joint Minerals and Waste Plan.

Hampshire County Council

(ID1221)

Safeguarded site off Chandlers Farm is located close to boundary with Bracknell Forest. It’s currently an inactive sharp sand and gravel quarry which contains reserves of sand and gravel and a concrete batching plant. Reserves likely to be extracted in the future and presence of site should be considered if there are any future development proposals in the area.


No comment.


Supportive of a new plan, but disappointed that commitment in old plan to sustain a meaningful gap between Sandhurst and Crowthorne has been abandoned (reference made to site SAND 5).

Policy coverage within Policy LP16 causes concern as omissions compared to previous Policy.

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There is no section of what a Local Plan is, what it does and how it is used.

The LPA needs to check every new policy to ensure there is no reduction in effectiveness/weight. Has there been an analysis of the effectiveness of a new policy over an old one (such as Counsel opinion).


Lack of obvious Masterplan with regard to housing provision, which should look towards the next 50-100 years. Questions why sites viewed as unsustainable 10 years ago are being allocated.

Winkfield is a large and diverse semi-rural parish; it essential that a balance between economic growth and protection of the country’s land assets is achieved. The public and local residents care about their local environment and do not wish to see it permanently damaged by excessive development. Concerned that old data is being used for projections, and whilst accepting the large cost implication requests that data is brought up to date prior to major planning decisions requests the following points are given consideration when sites in Winkfield are considered for development

• the halting of the erosion of the Green Belt • the halting of the erosion of the ‘gap’ separating Bracknell

from Ascot • the current highways infrastructure is inadequate and

additional traffic will cause further problems. • Lack of secondary school provision in the North of Bracknell,

children in the area are not able to attend the school of their choice, and none are within walking distance contrary to Government policy

• provision of local health services is under immense strain; without additional provision further development is unsustainable and will put lives at risk

• further development will exacerbate the low supply of water. • the inadequate local drainage and sewage systems cannot

cope with additional loading • the resultant adverse effects of further development on the

Special Protection Area • not enough support is given to business operating within the

Green Belt, leading to loss of potential additional local employment.


CONSULTATION PROCESS

Buffet (ID18), Balding (ID62), Exhibitions were useful/well presented/explained. Impressed with

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Lief (ID122), Coker (ID157), Murphy (ID650)

number of staff present. Staff involved were helpful and knowledgeable in answering questions, sharing concerns and explaining some of the issues in the Plan/provided clarity/pointing to relevant parts of the document.

(In some cases, specific exhibitions referred to: Martin’s Heron Community Centre, Binfield Library, Parish Office County Lane).

Willshire (ID78), Griffiths (ID83/84), Brown (ID133), Gamble (ID142), Dyer (ID166), Vinson (ID340), Phillips (ID1312)

Concerns regarding consultation process, attended an event at Carnation Hall but was very busy/high attendance/unable to speak to officers/room too small/too many people to be able to read the boards.

Willshire (ID78) Was only aware of events due to leaflet being put through door by Winkfield Row Residents Association, concerns that many local residents may not be aware of the proposals.

Griffiths (ID83/84) Early and meaningful engagement has not taken place. Documents too long and too complicated to understand. Difficult to register to make comments directly on the portal (gave up). Process not simple, seems the Council is trying to stop people commenting.

Reeves (ID98), Rogers (ID357), Ward (ID849, 1249), Gunn (ID1157), Fazey-Gunn (ID1237), Gaw (ID1389)

Difficulties entering and saving comments into the system/ doesn’t work in a standard browser, discourages public engagement/passwords not being recognised, having to be reset. Overly complicated registration system.

Williams (ID127) Lack of real consultation.

Brown (ID133), Vinson (ID340), Browne (ID1305), Browne (ID1307)

Poor communications to let BFC residents know what is happening/lack of publicity.

Brown (ID133), Bartlett (ID860), Taylor (ID581)

Time and number of slots available for the public were too few and inconveniently timed.

Dorman (ID137), Bruen (ID327, 329), Ward (ID849, 1249), Taylor (ID581), Glennerster (1128), Glennerster (ID1136), Glennerster (ID1236), Tuffley (ID1233), Gunn (ID1157), Fazey-Gunn (ID1237), Gaw (ID1389)

Inadequate consultation period (not enough time to understand and get an understanding of the information).

Hoad (ID151) Concerned that none of the comments made (at Carnation Hall) were noted/documented.

Hoad (ID151) Lack of proper consultation, no details of timescale for sites, land owner/developer details. Needs to be full disclosure. Value of land

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as arable compared to value for building should be disclosed.

Scanlon (ID151) Lack of consultation direct from BFC, found out via Facebook group. Consider meetings were badly run, representatives ill informed, and disinterested in local views.

Scanlon (ID151), Brett (ID188, Plan written in a way which confused residents/not in plain 189, 196), Bruen (ID327), English/accessible/difficult for average person to follow – legal & Vinson (ID340), Glennerster planning ‘speak’/jargon. (ID1128), Tuffley (ID1234), Browne (ID1305), Browne (ID1307), Phillips (ID1312), Gaw (ID1389)

Brett (ID188, 189, 196), Bartlett (ID860)

Insufficient information and true consultation provided.

Brett (ID188, 189, 196), Taylor (ID581), Tuffley (ID1233)

There is a significant amount of information to work through, including support document and evidence base – difficult to follow, not effective to layman.

Gourley (ID483) Commenting via the online system becomes unsecure, with warnings from security provider, so commented via email rather than online.


Disappointed that hard copy of documentation not available to the group on this occasion, unless they pay £50. Whilst a PDF is available to download, it is a long document to read on screen. Understand copies were available in public library and Parish council offices, but not practical to sit in the public places and take time to read the 287 pages. Hope that this was temporary, and in future consultations will revert to making a hard copy available without charge to established stakeholders who wish to respond. Question whether charging £50 meets the requirements for public consultation.

Mischefski (ID850), Mischefski Poor mechanism for consulting with residents of Crowthorne on the (ID852) draft Plan. Consultation needs to be improved and include a wide

range of consultation methods. Existing facebook pages and community magazines which were not utilised.

Vinson (ID340), Taylor (ID581) Council is avoiding conversations with the public in open forums. No public meeting with Council present. This was requested by the Winkfield Row Residents Association (who offered to host and chair at their own expense) and was refused/ignored).

Disagree with reasoning given such as from experience manned exhibitions are the best way to engage with residents and respond to questions/concerns. Previous exhibition in Warfield 10-15 years ago “turned into a riot”.

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Council is avoiding debating issues in an open meeting.

Vinson (ID340), Taylor (ID581) Difficult for resident responses to be evidence based – how can evidence be collected to challenge a plan produced by many months/years by professional staff?

Rogers (ID357) Public exhibitions admirable but omit key issue for Crowthorne, namely loss of strategic gap – meaning no comments will be received on a key change to the plan.

Bartlett (ID860) Website difficult to navigate.

Taylor (ID581) Note that the Statement of Community Involvement (2014) states it is the aim to “encourage community and stakeholder involvement (in planning)”- which seems to be as much consultation as the law required. The law does not stipulate that the Council needs to engage in any kind of dialogue with the public other than by email, post, consultation portal or broadcast media. Notes that BFBC went further than the legal requirement by holding a series of what were termed “manned exhibitions” (where public could view a summary of the Plan on small posters and ask questions).

Taylor (ID581) Disconnect with how the Council say they want to engage with the public and what they actually do. Residents have not been asked how they prefer to be engaged.

Council alone set up the methods of consultation, collects the ‘output’, determines what the output means, judges itself whether consultation has been successful – which is a closed top down system designed to avoid confrontation.

Taylor (ID581) Rightly or wrongly communities are resistant to change, however anger cannot be wished away by ignoring it. If refuse to listen, people come to believe they have no say and become cynical. Typified by a response to the consultation on the scope of the Local Plan in 2016: comment made was “No comment, as the Council makes decisions regardless of the public’s view.” Council’s response was “noted” which makes the authors point.

WRRA knocked on doors of those living in the area inviting people to get involved, with overwhelming response “Why should I bother? They (the Council) will just do what they want anyway.” The majority of people were convinced that it was not worth their while to make their voice heard, as nothing would result.

Collings (ID1089) The way in which BFC consults on Local Plans is, I believe, flawed. The main document is very long and fairly technical in nature. It is standard practice in other professions to produce a management, (in this case ‘resident’) summary for those who do not have the expertise or time to comment in detail. I am sure this would elicit

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more responses from a wider cross-section of the community. Of course, the more comprehensive document would still be available for those who wished to comment on it.

Glennerster (ID1136, 1235) Impossible to provide evidence in the allocated time.

Gunn (ID1157), Fazey-Gunn (ID1237),

A Town Hall style meeting should have been held to gain the attention of people.

Browne (ID1305), Browne (ID1307)

Did not attend any meetings as was unware of them. They should have been more widely publicised and notified residents.

Phillips (ID1312) Not all of the planning documents were available on the planning website at the beginning of the consultation.

Gaw (ID1389) Online consultation system no inclusive – no thought given to those without internet access.

Gaw (ID1389) Consultation events were information delivery events rather than consultation (information capture was not evident).

Campaign to Protect Rural England, Berkshire Branch (ID1528)

Expressed appreciation of the document, in particular the clarity and accessibility of supporting information and evidence. Thanks expressed to members of the Development Plan team who were spoken to during the course of the consultation, and for their helpful and friendly responses.

Bryant (ID490) Residents are spending their valuable time objecting, can you at least, restore their faith and their trust that their local Council will, make a decision which supports what they would like. Aren't you meant to be here for the residents? To hear what they would like in the place where they live? Have they not put up with enough already? When will this ever stop?

E and B Glasson (ID974) Concern that residents having seen so much damage to the environment despite opposition may feel that to communicate their feelings will be a waste of time.

Campbell (ID45) Plan omits crucial steps to align with Government housing aspirations, and fails to engage with Government wishes to make housing affordable again. There is a massive accumulated shortfall in housing supply, therefore policy needed over next two decades is to considerably increase the new housing supply in order to slowly return prices to affordable levels seen a generation ago. This omission in Plan makes it unsound. Plan needs to solve the supply deficit in a realistic way. The Plan refers to duty to co-operate obligations, but passes the responsibility of a futuristic supply solution to others – what will happen after the expiry of the plan period?

Ayres (ID158) Government’s definition of affordable is not what is needed locally, need housing that can realistically be afforded.

Murphy (ID1522) Part of housing allocations should be given over to allotments. Food security key theme for sustainability, encourage growth of local produce.

Horan (ID1310) Need is for large scale Council housing to meet the crying need for low-cost housing with some of it being 4 or 5 bedroom affordable family homes.

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Collings (ID1071, 1089) Para. 6.45 - Unclear why BFC is continuing to promote sites of multiple ownership (such as Hayley Green) when difficulties associated with these have been clearly demonstrated in Warfield (areas 1 and 3). BFC acknowledges this as an issue in para. 6.49 and that it has contributed to lack of 5 year land supply and unplanned development.

Phillips (ID538) Further land will become available in the future as British farming recedes further.

Hutchinson (ID535) Development in Bracknell area is for short term financial gains, not to preserve natural beauty of area.

CHARACTER

Griffiths (ID81) Building houses in a different style will change the character of the area (reference to draft Local Plan policies LP12 and LP18 in relation to development protecting, enhancing and positively contributing to the distinctive character of the local area, and the Character Areas Assessment SPD which summarises specific features of each character area).

Singleton (ID66) Queries whether the Core Strategy will continue to guide future development in the Borough, with reference to Policies CS7, CS9, CS23 and CS24. If policies will no longer guide development, which document will contain revised Core Strategy policies to guide future development?

Sturges (ID1254, 1301) Understand that more houses have to be built, but would like development sympathetic for existing villages.

LOCATION OF DEVELOPMENT

Ellingham (ID65), Dyer (ID166), Winkfield Row Residents Association (ID947)

Development should be focused on brownfield sites (closer to Bracknell centre), instead of greenfield/no brownfield Policy.

Cornwell (ID67), Reeves (ID107), Runham (ID495)

Regard should be had for opportunities for brownfield sites (some comments also refer to including those from the Brownfield Register). Concerned more green open spaces around Binfield, Warfield and Winkfield will be lost for future generations.

Gorlowski (ID470) Efficient use of brownfield land by demolition of low-grade housing to build flats would easily create number of homes required. E.g. ‘The Forresters’ could be redeveloped to flats.

Griffiths (ID81), Dyer (ID166), Gorlowski (ID470)

Empty offices in Bracknell could be converted to housing instead of building on green fields.

Brown (ID88) More should be done to identify agricultural sites which could be developed, not wildlife and ecosystem rich woodlands sites, just because they are available.

Hoad (ID151) 54% of the building target (3,216) will be achieved on 4 greenfield sites. 70% of the total target will be on greenfield sites. There should be a more balanced approach.

Hoad (ID151) Insufficient brownfield sites have been made available and insufficient disclosure has been made of unacceptable brownfield

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sites which were considered. Vinson (ID341) No evidence of a brownfield site policy as recommend by Ministry of

Housing in 2017. Vinson (ID341) No engagement with the public on the production of the Brownfield

Land Register. Glennerster (ID1136) Concerned about simply building on every available piece of land. Bracknell Friends of the Earth (ID1355)

Supports demolition of empty buildings in the town centre, and building new flats

Winkfield Row Residents Ministry of Housing April 2017 stated that “communities will be able Association (ID947) to highlight local derelict or underused building sites that are primed

for redevelopment. This can bring investment to the area and increase the number of new homes in the area”. The Local Plan should include a process to support this initiative.

CPRE commissioned report (December 2017) finds engagement with wider public and community in the production of Brownfield Land Registers has been limited, and recommends local authorities should explore ways in which to engage a wider range of stakeholder in creating the registers.

A more innovative approach should be applied by BFC. BFC currently plans to review and update the register annually, a minimum requirement only, why not more frequently?

Draft NPPF states planning policies and decisions should promote an effective use of land in meeting the need for new homes and other uses, and strategic plans should contain a clear strategy for accommodating objectively assessed need, in a way that makes as much use of previously developed or brownfield land as possible.


Brownfield site on Western Road. There is a large plot next to offices which have been empty for years which was previously due to be transformed into a Data. There are many offices in the area which have been vacated lately and some offices and working spaces which have been unoccupied. No justification left for any further office building in the area. This site is on the perimeter of housing directly adjacent to it at the back, so why is this not being designated for flats and parking? It is near the town centre, transport links, schools, services and greenbelt.

OTHER MATTERS

South East England Wildfire Does not address requirements of para. 164 of the NPPF in relation Group (SEEWG) (ID6) to wildfire mitigation and adaptation. Reference also made to

existing precedence contained in the Dorset Heaths Planning Framework, Former TRL site and Surrey Heath Borough Council documents.

(Further detailed comments also made in relation to the recent Thames Basins Heaths SPD consultation).

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Buffet (ID18) Not much consultation or change possible to the Plan in terms of proposed housing sites. (Sites were chosen from the SHELAA/BFC analysis of evidence, new substantive evidence is unlikely to be forthcoming at this stage. Capacity of selected sites just exceeds BFC housing target, so any changes would require reverting to other (already deemed less favourable) sites. If the proposed larger capacity sites were rejected, there may be no available alternatives, risking meeting the housing target. By the time individual planning applications are made for proposed sites, they will be part of the Local Plan, and there will be pressure to approve them, regardless of other considerations, i.e. the application process will be biased).

Hoare (ID59) The Plan should take account of the Winkfield Neighbourhood Plan which is at an advanced stage.

Vinson (ID179) Understand from Winkfield Parish Council’s response to the Draft Plan that it is different to what was shown to the Council by developers.

Phillips (ID538) Consider that objections will be ignored. Should look at the Warfield Neighbourhood Plan and work with Hayley Green village to bring about best outcome.

Bury (ID305) Considers that existing dwellings around BIN7 should not be added to the defined settlement; would like to remain outside the defined settlement.

Murphy (ID650) Typo on Policies Map – area SA9 labelled as SA5 incorrectly. Murphy (ID650) Drawing new settlement boundaries premature a) discrepancies in

evidence base documents i.e. Housing Background Paper: Basis of Allocation, b) preliminary/ incomplete evidence base, c) absence of design policy and d) differences with Neighbourhood Plan (in relation to LP7). If drawn, should include whole site. Also noted in Policy LP7.

Murphy (ID650) Extend protection of the Bullbrook north of Forest Road – make this small area part of LNR improving connectivity (contributes to WFD obligations).

Murphy (ID650) Unclear whether BFLP or Warfield Neighbourhood Plan will confirm outcome for LP7/ Cluster 7, in terms of number of homes, density etc. Need meaningful consultation. Question why no other allocation being treated in this manner.

Norman (ID634) Reference to Hayley Green Residents Group opposing Warfield Neighbourhood Plan (61 via online petition; >450 via paper (68% of all Hayley Green residents).

Murphy (ID628) Concerns over use of words ‘local community’ in para. 6.49; until Reg 14 consultation only landowners were involved in site options and decisions through the Warfield Neighbourhood Plan. Request wording is clearer.

Grinney (ID738), Murphy (ID787)

Residents were not aware of the Warfield Neighbourhood Plan proposals and had no input into proposals. Site at Hayley Green was decided upon and presented to residents in October 2016 without any prior consultation. Although comments invited after plan went public, no feedback ever received. Poll of objections presented to BFC in Sept 2017. Seems to be against fundamental idea of a Neighbourhood Plan. Quoting Warfield Neighbourhood Plan in

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BFLP therefore misleading. Collings (ID1071, 1089) Para 6.46. The Draft Warfield Neighbourhood Plan has taken far too

long to develop; attempts at community engagement have at times been poor. Very little consultation with residents on potential development site before the Hayley Green Policy (Policy 2) was presented to residents as a fait accompli. The Pre-submission consultation indicates an overall objection to the Plan’s Spatial Policy (Policy 1) and a more marked objection to the Plan’s Hayley Green Policy. Please do not use the emerging Warfield Neighbourhood Plan to justify development at Hayley Green since it has the potential to be rejected by Warfield residents should it ever reach a referendum.

Butcher (ID979) The draft NPPF (Consultation March 2018) para. 119 states:

"Local planning authorities, and other plan-making bodies, should take a proactive [my emphasis] role in identifying and helping to bring forward land that may be suitable for meeting development needs, such as sites included on brownfield registers or held in public ownership, using the full range of powers available to them".

This requirement should be included in the draft Plan. Tuffley (ID983), Tuffley (ID999) Plan is bureaucratic and written in planners spall. Not aspirational. Tuffley (ID983), Tuffley (ID999) No mention of Warfield Neighbourhood Plan - it is not listed. Tuffley (ID983), Tuffley (ID999) ‘We need consideration’ is not a fact. Richardson (ID853) There appears to be deficiencies in the Plan which questions its

soundness, including identification of potential housing allocations with significant constraints.

Richardson (ID858) Risk of potentially suitable sites for housing e.g. those identified via SHELAA can be frustrated by restrictive policies in an emerging Neighbourhood Plan.

Hobbs (ID1090) No mention of the effect of BREXIT. Colebeck (ID1302) Suggest BFC visit the area (Binfield). Timbrell (ID1398) Existing traffic issues, and poor health facilities (lack of doctors,

Frimley Hospital too far/cannot cope). Murphy (ID1522) Food security needs to be central theme of the Local Plan for

sustainability, encouraging the growing of local produce would contribute to this. Part of the housing allocations should include allotment sites.


Napper (ID56, 128) Error on map in relation to land at Sandbanks Long Hill Road. The Site Allocations Local Plan (map 31, page 127) shows the northern boundary of the site included by a small triangle within the existing settlement boundary, which was beyond the line shown on the OS map. The draft Local Plan (Fig 23, page 235 and Fig 24 page 237) shows the boundary incorrectly reverted to the OS line. This needs to be corrected.

Tingdene Developments Ltd (ID373,375), Bracknell Land Ltd

Response to Site Allocation Overview Maps. Support the proposal in Figure 9 to include residential areas for allocation within a revised

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(ID394) settlement boundary of Bracknell. It is possible that the area of built development could be different to that shown on Map 4, once further drainage investigations have taken place. Therefore, important to recognise that the boundary on Figure 9 should not affect or influence the master planning process for the site.

Tingdene Developments Ltd (ID374, 375), Bracknell Land Ltd (ID395)

Response to housing trajectory. The trajectory indicates 70 units would be delivered at the Hideout and Beaufort Part in 2027/28, with 100 units per annum thereafter. Consider this to be unduly pessimistic, and suggest that 50 units are deliverable in 2020/21, with 100 units per year there after, with the site fully complete by April 2027.

Eagle House School (ID725) Consider current countryside designation (Policy LP II) to be inappropriate as fails to recognise the school's unique history, attributes and role in the local area. It’s important that it continues to function effectively within its existing site.

Consider the draft BFLP and SALP to be inconsistent in their treatment of major institutions located outside defined settlement boundaries (refer to RMA, Sandhurst).

Recommend additional Policy and text:

"Policy x -Eagle House The area of land shown on the Policies Map (xx), the Eagle House Estate, is suitable for built development to meet the College's educational and operational needs provided that the site's heritage assets are sustained and, where possible, enhanced; any development does not have any adverse impact on the integrity of the Thames Basin Heaths Special Protection Area or the character of the countryside; and the height of any new development would not significantly exceed that of existing buildings on the"

"The Wellington College Estate is an important and historical educational institution which includes Eagle House and Wellington College. The College provides important national and local educational facilities. The Estate makes a significant contribution to the local economy and is a major local employer. It is important that it can continue to function effectively within its existing site.

The site contains a range of buildings, including some listed buildings and a large area of undeveloped land beyond the existing built envelope. The objective of the proposed policy is to ensure that the Estate can continue to carry out development required for operational purposes to enable it to maintain its status as a world class institution whilst protecting the listed buildings on the site together with their setting and avoiding any adverse impacts on the character of the countryside and nature conservation."

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Comment includes annotated version of Policies Map showing which parts of the estate should be covered by suggested policy i.e. key educational/operational areas within the school grounds.

Wellington College (ID720) Consider current countryside designation (Policy LP II) to be inappropriate as fails to recognise the College's role as a major institution and local employer (800 people with Eagle House). Also has a critical role in terms of providing facilities for the local community. Needs to be able to continue to function effectively within its existing site. The College has a unique history and attributes, which sets it apart from other educational institutions. Consider the draft BFLP and SALP to be inconsistent in their treatment of major institutions located outside defined settlement boundaries (refer to RMA, Sandhurst).

Recommend additional Policy and text:

"Policy x -The Wellington College The area of land shown on the Policies Map (xx), the Wellington College Estate, is suitable for built development to meet the College's educational and operational needs provided that: i. the site's heritage assets are sustained and, where possible, enhanced and the settings of the listed buildings are safeguarded from harm and, where possible, enhanced; i. any development does not have any adverse impacts on the integrity of the Thames Basin Heaths Special Protection Area or the character of the countryside; and iii. the height of any new development would not significantly exceed that of existing buildings on the site. "

'The Wellington College Estate is an important and historical educational institution which includes Wellington College and Eagle House. The College provides important national and local educational facilities. The Estate makes a significant contribution to the local economy and is a major local employer. It is important that it can continue to function effectively within its existing site. The site contains a range of buildings, including some listed buildings and a large area of undeveloped land beyond the existing built envelope. The objective of the proposed policy is to ensure that the Estate can continue to carry out development required for operational purposes to enable it to maintain its status as a world class institution whilst protecting the listed buildings on the site together with their setting and avoiding any adverse impacts on the character of the countryside and nature conservation."

Comment includes annotated version of Policies Map showing which parts of the estate should be covered by suggested policy i.e. key educational/operational areas of the College.

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Rumsey (ID 1447) Winkfield Triangle

Para 2.11 refers to Duty Co-operate Framework, and to the Evidence Base. D to C Framework in the Evidence Base is dated February 2016 so is not up to date. Para 2.11 refers to reporting being carried out annually in a monitoring report. Not clear if all other authorities support BFC approach, particularly on provision and quantum of housing. Also not clear whether Authorities outside defined housing market area, but related to the Borough in terms of housing and employment generation, agree with BFC approach.

Concerned about suggestion at 6.7 that BFC unlikely to need to assist with Reading’s potential shortfall in housing due to the Government’s indicative lower figure for Reading. This approach does not allow for Reading increasing its OAN beyond the standard methodology, to reflect growth aspirations, which would appear quite feasible and in line with emerging national guidance on the matter.

Rumsey (ID 1448) – Winkfield Triangle

Some of the Council’s assumptions on its housing requirements and supply are incorrect. An explanation of this is set out in a separate Housing Evidence Base Paper submitted with these representations.

Questions are raised on the capacity of a number of sites included within Tables 1 and 2. The suggested number of dwellings to be delivered from the sites referred to should be reduced.

Para 6.22 suggests a capacity of 3,651 dwellings from the sites listed at Policy LP3, the accompanying Housing Evidence Paper explains why this should be reduced to 2,930.


Map 2 of the draft Policies Map (Warfield and Winkfield north area) incorrectly labels the SA9 Warfield extension as SA5, which should be corrected.

Quod of behalf of Legal & Strongly support the retention of the former TRL site allocation, General Homes Communities through saved Policy SA5 of the Site Allocations Local Plan. (Crowthorne) Limited (ID1352)

Supports the strategic approach proposed by the Council in order to meet housing and economic need to 2034.

Also see comments on evidence base – IDP. Iceni Projects Ltd on behalf of Comments relate to site at Garth Hill, allocated in the Site CALA Homes (Thames) Limited Allocations Local Plan, with an overall capacity of 100 dwellings. (ID1418, 1419, 1422-1425)

The housing trajectory (appendix 1 of the Draft Local Plan) identifies 36 units on the remainder of the site over the plan period, as part of the site already has permission for 65 units (extra care apartments, application 13/00074/FUL). This is considered to be an underestimation of the expected number of further dwellings that could be accommodated ton the site, which would result in a density of around 12 dwellings per hectare, in a town centre location. An application on the remainder of the land has a resolution to approve subject to the completion of a s.106 for 89 units (application 17/01087/FUL). Consider the site to meet the three elements of sustainability (social, environment and economic) as set out in the

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NPPF.

Support the Council’s approach carry the allocation forward into the Policies Map of the emerging Local Plan. Also support the Council’s approach to meeting and exceeding their identified housing requirement over the Plan Period, but would like to highlight the opportunity for the Council to secure planning permission for a higher number of dwellings at the site than originally expected, as this assist in ensuring that the Council are able to meet and potentially exceed this target over the plan period.

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Comments on evidence base: General Comments

Comments on Evidence Base

General Comments





No comment.


Murphy (ID651) Evidence Base is well-organised, although not all documents were available or in their final form at the opening of the consultation on 8 February. There is far too much to absorb in 6 weeks, but it is preferable to be overwhelmed than not have access to source documents. It compares very favourably with other LAs in this regard.


None received.

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Comments of evidence base: LP/Ev/1b: Sustainability Appraisal

LP/Ev/1b: Sustainability Appraisal

(Also see comments on individual sites)





No comments.


No explanation provided as to what a sustainability appraisal is, how it is derived or used. Does it carry sufficient weight to get policies that have weakened due to new drafting amended to bring them back to full strength?


LP12 – Objective 4. Not likely it is certain unless the site is withdrawn/rejected.


Vinson (ID176) Plan contains too much development in areas which do not meet sustainability requirements. When the colour coded Sustainability results charts are reviewed, it is apparent that the BRA sites in central Bracknell show more green (higher rated) than the CLU5 and Hayley Green sites, which have few high sustainability ratings – how can the Council “prefer” sites which fail on many sustainability matters? A lot of work has clearly been done, but the logical conclusions do not seem to be drawn from outcomes. More BRA sites should be identified (such as empty commercial sites in central Bracknell).

Brett (ID188) No coverage of work undertaken in 2010 and the new findings. In 2010 there was a lot of information provided which included Winkfield.

Murphy (ID650) Detailed comments provided on objectives in relation to Cluster 7/ LP7: Agree with scoring – SA1, SA2, SA4a, SA6a, SA6b, SA7b, SA11, SA12, SA15, SA16, SA17 Disagree/ unsure with scoring – SA3, SA4b, SA10, SA12, SA18

Collings (ID1089) Non-Technical Summary N12 (p3) Ground nesting-birds in the south of the borough are being protected to the detriment of ground-nesting birds (skylarks) in the north of the borough. Some consideration should be given to addressing this issue.



SAND5. Lack of evidence to support comments in the sustainability appraisal such as it would not affect surrounding sites. Coalescence of settlements has not been considered in detail in the sustainability appraisal. (Also summarised in evidence base section relating to Policy LP3– SAND5).

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Murphy (ID650) Para 3.172 – WAR22 part of accessible open space focused only in east of site. Inappropriate given development is building across remainder of Hayley Green’s fields, thus impacting settlement and landscape character/ visual and landscape amenity for entire village. Loss needs mitigating for all residents (WAR22 at eastern edge).


Non-technical summary (N12, page 3). Ground nesting birds in the south of the Borough are being protected to the detriment of ground nesting birds in the north of the Borough, which should be addressed. (Skylarks are UK conservation status red, the highest conservation status, with the species needing further action).


Murphy (ID650) Scores in SA do not have LP7 as severely constrained by flood risk, despite extreme north east in FZ3 and much of rest of the site at risk of surface or groundwater flooding or both.

HIGHWAY MATTERS

Larks (ID8) Traffic. Vinson (ID182) Table 18 of the Draft Sustainability Appraisal states that

increased development is likely to generate additional vehicle movements, impacting congestion, travel time, air quality and noise. The base date information used in modelling is based at 2007, updated in 2013. Why has up to date data not been used?

Vinson (ID183, 184) (In relation to Winkfield Row)

Objective SA16 Services. Para. 3.189 states there is potential for CLU5 to be poorly served by facilities. There are no real plans for any built community facilities/hub including health facilities.

Objective 9 Economy and Employment. Individual elements are rated as neutral for the site, however the combined site has been rated as appositive. Aside from construction jobs, (that would be temporary), and some opportunities in the new school. What is the evidence to justify a positive rating?

Vinson (ID339, 340, 342) Plan does not have regard to sustainability requirements – sites should be chosen which achieve the highest sustainability ratings. Preference for Cluster 5 and 7 ignore the fact that they are poorly located, suffer from traffic and score poorly in the Sustainability appraisal results charts. Section 3.196 states further work is required to determine the nature and significance of effects and the measures required to prevent, reduce and

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offset any adverse effects. The Plan cannot be effectively assessed until this work has been completed and results shared with residents.

BRA sites in central Bracknell score better in terms of sustainability – more sites should be sought in that area.

Murphy (ID650) Table 12 (p.89): scores for SA objectives and in particular Objectives SA15, SA16, SA17, confirm that continued lack of accessibility and local services/facilities for Cluster 7 and constituent sites is anticipated.

Murphy (ID650) Para. 3.163/ 3.189 – traffic levels on rural road network including Hayley Green likely to be unsustainable despite stated junction improvements on Forest Road (cumulative SALP and BFLP allocations).

INFRASTRUCTURE

Murphy (ID650) Para. 3.163 and Para 3.189 contradict each other (opportunities for sustainable development vs potential for proposed allocations… poorly served by facilities). Refers to Draft Transport Accessibility Statement, IDP, SA Table 12 also (summarised under evidence base).

Murphy (ID651) Water resources & Water supply - Unclear why SA appraisal and site suitability summary in housing background paper include a green tick for objective SA7b. No issues that cannot be resolved are identified; low risk of adverse impact of development recorded despite no improvement to the current situation.

OTHER MATTERS

Gaw (ID1389) Cluster 5 – Table 12 - this site scoring is the highest negative score of all sites? One key issue is transport links with 25% of the sustainability objectives ranked as very negative.

Criteria for site evaluation appear ‘woolly’ and hard to define. This needs to be explicit.

It is acknowledged in the sustainability appraisal that further work is required to determine what measures need to be put in place. There has been no viability study produced as a marker to which objectively and effectively assess the Draft Plan.

Gaw (ID1389) Cluster 7 - The BFLP draft policy LP7 ranks Hayley Green in the bottom group for transport accessibility, additionally there are no demonstrable improvements indicated to discourage car use. The Draft Sustainability appraisal determines no new community facilities provided albeit developer contributions would be made to a community hub elsewhere. This does not promote the core

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sustainability markers and make Hayley Green a sustainable community.


Tingdene Developments Ltd (ID376), Bracknell Land Ltd (ID396)

Footnote 7 of the draft sustainability appraisal states that the draft Habitats Regulations Assessment has identified potential air quality effects from all residential developments identified in Policy LP3 on the integrity of the Thames Basin Heaths SPA and the Windsor Forest and Great Park SAC, but likelihood is yet to be determined. Note that the Council is working with Natural England to development a methodology for an air quality assessment, to be carried out at the submission stage. The air quality assessment is part of the evidence base under pinning the plan, and should therefore take place prior to submission of the plan for examination.

(also summarised under Policy LP39) Tingdene Developments Ltd (ID377, 378), Bracknell Land Ltd (ID397)

Para. 3.138 of the draft sustainability appraisal identifies the risk of grown water emergence in conjunction with surface water flood risk at The Hideout and Beaufort Park, and this underpins the negative score that the site has received in the sustainability appraisal in relation to climate change adaptation. However, para. 3.138 recognises that further technical investigation is required. Given the potential significance of this issue, wish to discuss the work that is required with the Council as soon as possible.

(also summarised under Policy LP4) Pegasus Group for the Whitaker Family (ID1498-1507)

Concerns raised in SA regarding site WAR10 are largely overcome by reduction in area for development as proposed by allocation.

Pegasus for Rumsey (ID 1464) The SA and scoring for land at Winkfield Row relates to a site area (CLU5) that has now been reduced in scale in the allocation at LP6. A separate submission relating to land at Winkfield Row (LP6) comments upon the individual criteria assessed. Consideration and scoring of the now allocated site, would represent an improvement on the original larger area scored in the SA.

Alfred Homes (ID1446) Land east of Ronans, Winkfield The site is an area of unmanaged grassland enclosed by mature trees and undergrowth. It is separated from Ronans and the associated managed gardens and landscape by a timber fence, mature trees and grassland. Table submitted showing how site complies with each of the three dimensions of sustainable development. Economic - Housing development is a key component of economic growth. Efficient use of a vacant site adjacent to the existing settlement boundary. Will contribute positively to the local economy.

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Social - Will contribute towards the housing needs of present and future generations. Consider it to be well served by a good range of facilities/services, including a number within 500m of the site (list facilities). Environmental – Proposed development could respond sensitively and create improvements e.g. Landscape Planting Plan, Surface Water Drainage Strategy. The Draft Sustainability Appraisal indicates that the Council ‘screened out’ the site and discounted it for prospective allocation. Due to various concerns (page 110). Provide comments on these concerns. Refer to technical assessments submitted with planning application 17/01051/FUL including LVIA ,Landscape proposals, Heritage Statement, Flood Risk & Drainage Assessment, AIA and Tree Protection Plan. All should have been considered in assessing sustainability. The Council’s analysis is not considered robust. The site is sustainable, developable, and there are no known impediments or viability constraints that would prevent this site coming forward. If site LP6 is proposed for allocation, it is logical that Wink7 should also come forward for development (compare the suitability of ‘Land east of Ronans’ to ‘Land at Winkfield’.

Bewley Homes (ID1493) The SA is not considered to provide a fair and reasonable assessment of land at Brookfield Farm (WAR 12) – accompanying document explains in detail. The only aspect of the assessment that appears to have resulted in the site not being allocated relates to the ‘Local Gap’ and setting of settlements.

All other issues raised within the SA summary (fluvial and surface water flood risk, presence of trees, potential impact upon listed building, potential for contamination, and location on a minerals deposit) are similar to many other sites that have been allocated.

No justification for the SA to conclude that the site is not suitable for allocation.

Gladman (ID1582) The Local Plan should be based on an SA process that clearly justifies its policy choices. It should be clear from the results of the assessment why some policy options have been progressed, and others have been rejected. Undertaking a comparative and equal assessment of each reasonable alternative, the decision making and scoring should be robust, justified and transparent.

Sites should not be discounted from consideration without being appraised on a like-for-like basis with the option that is ultimately preferred within the Local Plan. The SA must positively reflect the Planning Practice Guidance.

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Persimmon Homes North The Plan is supported by a Sustainability Appraisal (February London (ID1400) 2018). The SA considers the allocation of sites in the

countryside and concludes that allocating a mix of different sized sites would be most appropriate. However, it does not go further than this to include an assessment of sites in the countryside and does not therefore demonstrate that growth can be sustainably achieved in the Borough over the plan period. The failure to undertake a sustainability appraisal which demonstrates that sustainable growth can be achieved results in the Plan not being positively prepared and being found unsound. (Also summarised under section 5.1).

Barton Willmore on behalf of Harrison Housing (ID1063 & 1065)

WAR8 Land between Newell Hall and Cuckoo Cottage, WarfieldStreet

The Sustainability Appraisal (also summarised in omission sites) includes reasons for not allocating the site, addressed below:

Local Gap. Note the emerging Warfield Neighbourhood Plan has not yet been submitted to the Council, nor draft consultation carried out, nor assessed by an independent examiner. Therefore it should not be afforded significant weight. Comments also made on the principle of allocating a gap within a neighbourhood plan. There is no basis for gaps within the NPPF or PPG, or revised NPPF. Reference made to the independent examiner report on Sonning Common Neighbourhood Plan which recommended a gap policy was deleted.

Surface Water Flood Risk. Note there is a small high-risk area on the eastern boundary. Any development would be stepped away from the boundary due to significant tree coverage. In addition, subject to a drainage strategy, impermeable areas would be minimised, and Sustainable Drainage Systems incorporated.

Adjacent to Listed Buildings. The indicate layout takes on board comments from the Council’s heritage through the pre-application. A significant western buffer would be retained with additional planting to ensure the setting of the listed building is protected, and a proposed L-shaped building to be subservient to the listed building.

Site covered by trees. The site is not covered by trees, the majority of trees are located close to the boundaries. This is supported by a tree survey. Whilst there are saplings within the centre of the site, the trees of higher quality are around the boundaries, and could be retained as part of any development.

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Medium Ecological Value. A preliminary note provided which recommends mature trees and vegetation around the boundaries are retained to support pipistrelle bats. The note also recommends further work is undertaken to ascertains whether ponds in the area surrounding the site support Great Crested Newts. Further work undertaken by EPR with E-DNA show no ponds with a Great Crested Newt within 250m of the site, and no further surveys recommended.

Landscape Sensitivity. Any development would incorporate existing tree coverage as well as adding trees on the western boundary to create a buffer with the listed building. The proposal would consist of a large single building set back in the suite, consistent with neighbouring buildings. The site should be viewed in the context of the north Bracknell strategic allocation, located south of the site.

Turley on behalf of Knight and WINK7 Alfred Homes (ID1446) Ronans, Forest Road, Winkfield Row

(Also summarised in omission sites). Reference made to the planning application information accompanying application 17/01051/FUL, which were not considered as part of the Sustainability Appraisal process. Comments made on the sustainability appraisal of the site in relation to: Landscape sensitivity. LVIA submitted demonstrates that the King George V Recreation Ground makes the greater contribution to the perceived openness of the area; the village character; and, the break between areas of residential development, than the site. Poor relationship to existing settlements. LVIA submitted for application 17/01051/FUL demonstrated that the proposals are visually contained from the wider landscape and do not contribute to the visual separation of Winkfield Row North and Winkfield Row South. Forms the setting of adjacent grade II listed building – medium heritage value. Having considered the limited extent to which the application site contributes to the special architecture and historic interest of Ronans and the character and appearance of the Winkfield Row Conservation Area, together with the Landscape Strategy and the form and appearance of the proposed development in 17/01051/FUL, the Heritage Statement concluded that there will be no harm to the significance of these heritage assets. Proximity to Conservation Area. As above. Groundwater and surface water flood risk. The Flood Risk & Drainage Assessment (Appendix 5) proposes a drainage solution involving an attenuation pond to the north west of the site providing further storage volume, upstream of the controlled outfall to the existing ponds. The proposed pond

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falls within public land, enabling long term maintenance. Protected trees on site. The AIA and Tree Protection Plan submitted with application 17/01051/FUL (shows the majority of existing trees being retained. Five trees are to be removed as they have been identified as being of a poor condition and not viable to retain. One small tree group and two individual trees are also proposed to be removed to accommodate the access road and construction activity. Given the potential for additional planting, this is not considered to be a constraint to delivery.


BRA1 Land at Parkview Farm, Old Wokingham Road (Also summarised under omission sites) Broadly supportive of the overarching methodology, but question factors taken into account in scoring SA1 (mitigate climate change), SA12 (health), and SA17 (travel), resulting in double counting of scoring.

SA1 draws upon Appendix 1 of the Draft Transport Accessibility Statement do objectives SA16, SA17 and SA12. Implications of double counting are if a site scores well against criteria in the Accessibility Statement, the positive score is multiplied by a factor of at least two, and conversely if the site scores less well, the negative score is multiplied. Revised scoring provided to remove the bias. Consider that as the SA moves forward, double counting should be eradicated from the scoring. The SA does not include comprehensive evidence or commentary on the scoring process that has been applied to each of the proposed allocations and excluded sites against the SA criteria (although notes the Housing Background Paper does provide some high level commentary pertaining to the scoring criteria included in Tables 12 and 13). For example scoring given to the land at Parkview against criteria SA6b – Wastewater, where a double negative result is recorded on the grounds that major constraints have been identified. The source and nature of the stated major constraint does not however appear to have been documented within the SA or the referred published Phase 1 Water Cycle Study (December 2017).

The key issues are the reasons given by the Council for not allocating the site include, which are disputed: the site has a poor relationship with the existing settlement the site is an isolated location within the countryside in an area that acts as a strategic gap the site is judged to have medium-high landscape sensitivity fluvial, surface water and ground water flood risk presence of trees along boundaries there are areas of high ecological value the site partly contains a Local Wildlife Site/Ancient Woodland high historic landscape value and the presence and setting of an adjacent listed building within the setting of an archaeological asset changes in level

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across the site, and potential for odour from nearby Wastewater Treatment Works.

Comments on SA scoring: Objective SA1 – Mitigate Climate Change The site has the opportunity to provide sustainable development in relation to transport infrastructure, and good access to services. Preliminary transport strategy (TS) provide provided. This identified that contributions could be made from the site for joint highway safety improvement at the junction of Easthampstead Road/Old Wokingham Road and two other junctions at Old Wokingham Road/Waterloo Road and Wold Wokingham Road/Nine Mile Ride. The TS also identifies the opportunity to facilitate a bus loop through the site, and improved pedestrian and cycle connectivity. As per the Council’s Transport Accessibility, the site scores well in its locational sustainability. The TS concludes there are no transport related grounds why the site does not represent a suitable and accessible location for development, therefore consider it would have a neutral effect ion the SA objective overall.

Objective SA3 – Biodiversity Phase 1 Ecological Appraisal has been undertaken on the sit. Which confirms the site is dominated by agricultural land of a mix of arable and semi-improved grassland which is of negligible to low ecological value. Within the contest of the site, the field boundary features are conclude to be elevated in value. Development of the site could therefore retain with appropriate reinforcement the boundaries of the site. The study also concludes that retention of the small areas of the onsite non-statutory designated Local Wildlife Site (LWS) small area of Ancient Woodland situated in the north of the site could be avoided through sensitive design layout. Therefore conclude that the site would have a limited negative impact on biodiversity connectivity and neutral scoring against the SA objective.

Objective 4a – Landscape A Landscape and Visual Appraisal (LVA) has been undertaken on the site, and a rebuttal in relation to the Council’s assessment of the site. The LVA confirms the site is not visible from a wide surrounding area and the surrounding mature vegetation would be of benefit in providing early visual enclosure and partial screening of any built development on site, and there are no overriding landscape or visual constraints associated with the site that preclude development. It is acknowledged that the key sensitivity relates to the strategic gap between Bracknell and Wokingham, and the landscape setting of Easthampstead Park, but concludes that this can be addresses through location of development, and strategic planting belts to visually and physically enclose the site. Therefore, consider the site has a

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medium landscape sensitivity, and the development can include mitigation of impacts.

Objective SA4b – Historic Environment A Built Heritage Assessment and Archaeological Desk Based Assessment (ADBA) submitted which concludes that Old Oak Farm, The Clockhouse and Old Oak Court (all Grade II), Locks House (Grade II*), Locks Barn, the barn at Sutton Court Farm and stables at Sutton Court Farm (all Grade II) are sufficiently removed and screened that the site does not currently contribute to their respective settings. Primary identified consideration relates to the setting of Easthampstead Park (Grade II), acknowledges there will be some impact to the setting through direct views from The Avenue, but could be mitigated by stepping development away from eth eastern boundary, and provision of strategic landscaping. Also recommends that the Bridleway crossing eth site should be retained as a footpath route to perverse its character as a historic route contributing to the setting. The ADBA confirms there are no designated heritage assets recorded on the site. The SA scoring should therefore reflect the above from a negative scoring.

Objective SA9 – Economy and Employment Promotion of the site includes a new community facility, a health facility and co-working space and land for a new Primary School. Development of the site will therefore facilitate job creation and economic growth providing employment opportunities supporting a successful, competitive and balanced local economy for the area, and will have a positive impact, and the SA scoring amended.

Objective SA15 – Community The site is in close proximity to a range of facilities including local schools and facilities at Jennetts Park. Promotion of the site also includes on-site facilities. The SA scoring should take account of this and be amended from neutral to positive.

Objective SA16 – Services Reference made to the Residential Accessibility Assessment used to assessment the sites. Sites BRA3 & BRA4 of +14 which has translated to a single positive score in the SA, where as this site overall score has translated to a positive and negative scoring. Comparative scoring appears misplaced, given that BRA3 & BRA4 are further away from strategic employment locations, centres and health facilities than Parkview Farm. Therefore either the scoring for BRA3/BRA4 should be downgraded to match Parkview Farm or vice versa.

Objective SA17 – Travel Development of the site would dissipate traffic to the strategic road network and provide opportunities to secure contributions

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for junction improvements in the local area to the site. Pedestrian and cycle access can be accommodated within the development, bus route linkages can also be facilities. Therefore consider the site would have a positive effect on the SA objective.


Policy LP4. Land at the Hideout and Beaufort Park, Nine Mile Ride, Bracknell.

(Also summarised in LP4)

In relation the SA, this has been assessed in two parts, whereas other sites such as Hayley Green have been assessed in a single entirety, which is considered to have artificially resulted in the site appearing more sustainable than if assessed as a whole. There is no clear justification for splitting the site.

Detailed comments made on the SA scoring: Biodiversity (SA3) Does not take account of the potential to impact on protected specifies. In the Council’s Phase 1 Habitat Survey, Beaufort Park includes breeding site of the woodlark, no mitigation has been put forward, which should result in a negative score. Significant woodland cover would be lost, which should be reflected in the scoring.

Landscape (SA4a). Scores negatively, however the landscape sensitivity appraisal indicated the cluster scores medium to high. As the sites will be allocated as a single site, cluster scores would be more appropriate, -3 overall.

Economy and employment (SA9) Council’s SA assessment of BRA3 indicates a score of -1. However, development of the site would not result in any direct gain or loss for the economy or employment in terms of longer term land use. This site should therefore be scored 0 in line with SA methodology. Same for BRA4.

Land Use (SA18) BRA3 adjoins existing development to the east. When the cluster is assessed as a single entity BRA3 should receive the same score as BRA4 (i.e. -1).

Revised overall SA score In summary, when applying the revised scoring, Cluster 3 receives an overall SA rating of -8.

The Housing Background Paper identifies a high pressure gas pipeline as a constraints, but this is not considered in the SA. This could affect the developable area. At present, it is not clear

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what the impact might be in terms of capacity/developability. The SHELAA identifies the site is in multiple ownership, which may restrict comprehensive development. Other site without ownership constraints are availability such as Parkview Farm.

A previous application (15/00826/OUT) for the Hideout element of the site was refused in late 2015 for 112 dwellings and other uses by the Council on a number of grounds.


Policy LP5. Land south of London Road, east of Bog Lane and west of Swinley Road (Whitmoor Forest), Bracknell (SITE WINK22)


Detailed comments made on the SA scoring: Climate Change (SA1) This score is derived from the overall score measured against the indictors set out in the Transport Accessibility Assessment (2017). There is a difference in scoring between 2010 and 2017 version of the Transport Accessibility Assessment. Circumstances have not changed significantly, therefore no justification for the divergence in scoring (2010: -1.5, compared to 2017 score of 7). It is considered appropriate to apply the 2010 assessment scores, which would indicate the site should score 0 in line with the SA.

Biodiversity (SA3) Site scores -2, but does not take account of impact upon protected species. , as the site supports populations of Great Crested Newt and Nightjar. Development of the site would impact on biodiversity interest of more than local significance, so would be scored -3.

Health (SA12) The Council’s SA scores the site as 0 against this objective. However, the site is well related to three areas of significant open space. It is reasonably related to leisure facilities which are largely located within Bracknell. The site is not constrained by any public rights of way nor by traffic congestion. On this basis the site should be assessed as having a score of +2.

Revised overall SA score This should score -5 instead of the current -2.

The SHELAA indicates there are restrictive covenants on the land. On the basis of the information provided, the extent of the covenant restriction is unclear, and there is no certainty this could be overcome, and be developed within the plan period, so it should not be included in the Plan.

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The footnote for Policy LP5 set out in the Draft Local Plan indicate that the:

‘Total final number to be subject to further consideration of the impacts on the heritage assets’

At this stage, there is no certainty that the number of dwellings indicated in the Local Plan can be delivered. Alternative /additional sites should therefore be considered to ensure the Council is able to meet its housing need (such as Parkview Farm).


Policy LP6. Land at Winkfield Row. (Cluster 5)


Detailed comments made ion the SA scoring: Climate Change (SA1) This score is derived from the overall score measured against the indictors set out in the Transport Accessibility Assessment (2017). There is a difference in scoring between 2010 and 2017 version of the Transport Accessibility Assessment. Circumstances have not changed significantly, therefore no justification for the divergence in scoring (2010: -2.5, compared to 2017 score of 0. It is considered appropriate to apply the 2010 assessment scores, which would indicate the site should score 0 in line with the SA.

Biodiversity (SA3) The site has some local ecological value potential as a UK Priority Habitat and grassland has been identified for reptile and great crested newts. . Any local impact on the ecology could be mitigated through implementation of the development. The site should therefore be scored -1 in line with the Council’s SA.

Groundwater source protection one (SA7a) Regional Agricultural Land Classification Map, the site is Grade 3 agricultural land. It is not within a Source Protection Zone and is not constrained by waste considerations. A small section at the northern boundary is located on mineral deposits but this is unlikely to constrain development. In line with Council’s SA, the site should be scored -2.

Economy and employment (SA9) The Local Plan identifies a school will be delivered as part of the allocation, and it is agreed that this is an employment generating element of the scheme. However, for consistency, this benefit should result in the same scoring as attributed to Hayley Green, which also proposes a school, i.e. zero (and is reflected in the revised SA scoring or Parkview Farm).

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Revised overall SA score This should score -17 instead of the current -20. There are multiple ownerships within the suite which could affect comprehensive development and timing. Other alternative sites within the restrictions should be considered such as Parkview Farm.

The footnote for the Policy set out in the Draft Local Plan indicate that the: ‘Total final number to be subject to further consideration of the impacts on the heritage assets’ At this stage, there is no certainty that the number of dwellings indicated in the Local Plan can be delivered. Alternative/additional sites should therefore be considered to ensure the Council is able to meet its housing need. A previous application (14/01333/OUT) was refused on parts site for 88 dwellings. The subsequent appeal (PINS Ref: APP/R0335/W/15/3137269) was dismissed primarily on the grounds of unacceptable visual and landscape effects of the development which would not be mitigated by landscaping or the provision of some open space.

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Comments of evidence base: CLP/Ev/2b: Bracknell Forest Gypsy and Traveller Accommodation Assessment (GTAA) (arc4, October 2017)

CLP/Ev/2b: Bracknell Forest Gypsy and Traveller Accommodation Assessment (GTAA) (arc4, October 2017)

No comments received.

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Comments of evidence base: CLP/Ev/2c: Strategic Housing Market Assessment (SHMA) (GL Hearn, February 2016)

CLP/Ev/2c: Strategic Housing Market Assessment (SHMA) (GL Hearn, February 2016)

See comments on Section 6 of the Plan.

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Comments of evidence base: CLP/Ev/2d: Western Berkshire Housing Market Area Strategic Planning Framework (GL Hearn, February 2016)

CLP/Ev/2d: Western Berkshire Housing Market Area Strategic Planning Framework (GL Hearn, February 2016)


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Comments of evidence base: CLP/Ev/2e: Housing Background Paper (BFC, February 2018)

CLP/Ev/2e: Housing Background Paper (BFC, February 2018)

Also see comments on specific sites.




None received.


Murphy (ID651) Detailed comments about the consistency of the Housing Background Paper and Landscape Sensitivity Appraisal in relation to LP7. Comments on context plan and consistency with the Basis of Allocation in Housing Background paper. All summarised under LP7.

Murphy (ID651) Detailed comments provided on Landscape Sensitivity Appraisal, Draft Historic Environmental Assessment and SFRA/ Flooding. These comments have been summarised under the relevant evidence base document, and in LP7 where site specific.

Murphy (ID651) Text for LP7 does not accurately convey the overall score for Cluster 7 in Draft Transport Accessibility Statement was 0 (Section 6, Table 10) – which is the lowest rank group of sites (band 4). No other Band 4 sites allocated. So negative aspects outweighed by positives (lack of nearby congestion hotspots’ ‘fair access to education’). Text should indicate poor score, as per Draft SA scores SA16 and SA17.

Murphy (ID651) Cluster 7 - Ecological Assessment - Map does not seem to accurately reflect evidence presented in Phase 1 Ecological Assessment. Evidence also incomplete (recognised by authors). Therefore rankings and advice not based on sound information or evidence. Draft conclusions provided in BFC response (pg. 18) on Warfield Neighbourhood Plan differ to the final published study.

Murphy (ID651) Cluster 7 - Ecological Assessments – bullet 3, unclear when woodland in WAR15 cut down. Historic OS maps referred to. Maps show woodland along west side of Hayley Green Lane, and show trees northern part of WAR13 – where some oak trees survive today (figure 2.1).

Murphy (ID651) Ecological assessments of Cluster 7 - Study does not consider wider area – hopes Green Infrastructure will be addressed in future assessments. Detailed comments on evidence summarised under relevant evidence base document.

Murphy (ID651) No comments on ‘Noise, Air Quality and Contamination Assessments’ or ‘Minerals Assessments’.

Murphy (ID651) Detailed comments provided on ‘Other infrastructure requirements/ impediments’ – related to sewage events in Hayley Green/ Winkfield Row. Summarised under LP7 ‘drainage’.

Murphy (ID651) Detailed comments provided on Green Infrastructure, summarised under LP7. Also comments on the ‘Green Infrastructure Review’ evidence base study, which are summarised under this document.

Murphy (ID651) SA and site suitability summary – shows LP7 as unsustainable location, yet considered suitable for allocation. Comments on evidence base provided elsewhere need review and possible reconsidered decision. Have opportunity to argue case against

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Comments of evidence base: CLP/Ev/2e: Housing Background Paper (BFC, February 2018)



allocation more effectively due to large evidence base, compared to Warfield Neighbourhood Plan.

Murphy (ID651) Comments provided on capacity assessment, including developable area assessment, open space assessments – these are summarised under Policy LP7.

Murphy (ID651) Concern that evidence from draft HRA not been factored in to allocation of LP7.

Murphy (ID651) Comments provided on Recommended Approach – Basis of Allocation. Summarised under Policy LP7 ‘Other Matters’.



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Comments of evidence base: CLP/Ev/3a: Functional Economic Market Area (FEMA) (NLP, February 2016)

CLP/Ev/3a: Functional Economic Market Area (FEMA) (NLP, February 2016)


447

Comments of evidence base: CLP/Ev/3b: Economic Development Needs Assessment (EDNA) (NLP, October 2016)

CLP/Ev/3b: Economic Development Needs Assessment (EDNA) (NLP, October 2016)


448

Comments of evidence base: CLP/Ev/3c: Retail and Commercial Leisure Study (GVA, April 2017)

CLP/Ev/3c: Retail and Commercial Leisure Study (GVA, April 2017)


449

Comments of evidence base: CLP/Ev/3d: Approach to Employment Areas Assessment (BFC, February 2018)

CLP/Ev/3d: Approach to Employment Areas Assessment (BFC, February 2018)


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Comments of evidence base: CLP/Ev/4a: Open Space and Sports Study (BFC/Sarah Moore Consultant, August 2017)

CLP/Ev/4a: Open Space and Sports Study (BFC/Sarah Moore Consultant, August 2017)

See comments on Section 20 of the Plan

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Comments of evidence base: CLP/Ev/4b: Playing Pitch Strategy (BFC/4 Global)

CLP/Ev/4b: Playing Pitch Strategy (BFC/4 Global)

See comments on Section 20 of the Plan




Sport England (ID1047) Sport England has worked with the Council and the National Governing Bodies to prepare an up-to-date Playing Pitch Strategy which can help inform the Council's Local Plan. Chapter 10 of the PPS included 'other sports' and included some analysis of indoor sports facility. Sport England notes the following;

"10.19 A quality analysis of Other Sports Facilities was not undertaken so there is no data is available.

'10.28 Whilst there has been no analysis of specific demand for other sports facilities in the borough."

There has therefore been no detailed analysis of the quality of these facilities in the borough or demand for them. Sport England considers that additional work should be undertaken to understand what the Borough's needs are for these sports facilities in the future, covering quality and demand. Please see Sport England's guidance document; Assessing Needs and Opportunities Guidance;

https://www.sportengland.org/facilities-planning/planning-for-sport/planning-tools-and-guidance/assessing-needs-and-opportunities-guidance/

Sport England is concerned that the Council does not appear to be planning for any further indoor facilities (or improvements to its existing facilities) to support its increased population and it is important that the Council addresses this (see also comments in relation to the Infrastructure Delivery Plan below).

Sport England will object at the next stage of the Local Plan consultation if these matters are not addressed. Please contact Sport England to discuss this matter further.


None received.


None received.

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Comments of evidence base: CLP/Ev/4c: Water Cycle Study (JBA Consulting, December 2017)

CLP/Ev/4c: Water Cycle Study (JBA Consulting, December 2017)




Environment Agency (ID1270) Phase 2 WCS will consider Infrastructure capacity for sites outside clusters 1 to 6. Important to establish if all proposed sites can feasibly be connected to public foul sewer within the proposed development time frames. It indicates at an early stage if capacity needs to be increased and helps determine if capacity can be provided prior to occupation of development. Noted that foul sewer network capacity has not been considered. Important this occurs in the next phase of the WCS.

Environment Agency (ID1270) Report divides proposed sites into ‘clusters’. Unclear which sites are included within clusters and those not assessed. With the water quality assessment, it is important that the full quantum of growth proposed within the local plan is assessed.

Environment Agency (ID1270) Unclear when the phase 2 outline WCS will be completed. Essential it is provided in advance of the final stage of the local plan to ensure soundness.

Environment Agency (ID1270) Scoping report does not demonstrate growth can occur within environmental capacity. Important the local plan contains site allocations that can occur without detriment to the WFD objectives (no deterioration and getting to good status).

Environment Agency (ID1270) Section 5 (Wastewater collection) states that ‘In some rural areas of Bracknell, there are known issues of surface water drainage to foul-only systems, possibly as a result of misconnections or failure of soakaways.’ It is important that any developments within these areas do not exacerbate this issue and developers provide evidence they will take measures to keep foul and surface site drainage separate. During times of high rainfall or high groundwater, STWs may become overloaded with additional flow resulting in sewer flooding and use of storm overflows, posing a risk to water quality. This may worsen as more development occurs in those areas.

Environment Agency (ID1270) Encouraging to see adoption of catchment based modelling to assess impact of growth. This enables a cumulative assessment of all growth simultaneously which is an advantage over RQP software. The methodology section (6.5.2) states that ‘assuming an existing SIMCAT model is available for the catchment…’ EA believe a trimmed model was provided to Bracknell Forest Council in September 2017.

Environment Agency (ID1270) A number of sites have been identified in Appendix B as ‘Red’ meaning infrastructure upgrades will be required and there are likely to be constraints to these upgrades. As infrastructure capacity is identified as a potentially constraining factor for the local plan, it is recommended wording is included within it requiring developers to ‘demonstrate, at planning application stage or earlier, that there is adequate capacity both on and off site to serve the development.’ This could be in the form of a Foul and Surface water drainage strategy, including evidence they have consulted with the sewer undertaker regarding available capacity to accommodate increased flows.

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Comments of evidence base: CLP/Ev/4c: Water Cycle Study (JBA Consulting, December 2017)



Environment Agency (ID1270) Where current dry weather flows were found to be greater than the 2013-2015 dry weather flows, the greater of the two has been used. This is a precautionary approach and ensures any growth in the plan completed after 2015 has been incorporated into the baseline. It would be useful to have some transparency over the modelling figures.

Environment Agency (ID1270) Section 10.1 states there are no strategic scale water/wastewater constraints on growth. However, this is not strictly true and doesn’t appear to reflect matters earlier in the report (i.e. Ascot and Easthampstead Park flagged as ‘Red’).

Environment Agency (ID1270) Table 9-2 suggests climate change and its impact have not been assessed but the impact of pressure is potentially High for wastewater collection and Medium for wastewater treatment. More information could be provided as infiltration problems have been identified within Bracknell Forest Borough. Advised to consider what impact climate change may have on this current issue.

Environment Agency (ID1270) Questions 7 and 8 in table 6-17 only mention the short term flows, however it is longer term flows that have been identified as a problem. At Ascot, flows may already be an issue as they are exceeding their dry weather flow permit limit

Environment Agency (ID1270) Some of the figures provided are of a poor quality which makes it difficult to interpret, for example Figure 2-2 and 2-3. Some permit limits in Appendix A are probably not relevant and could be removed. For example Aluminium permits. Those relevant to this study are Ammonia, BOD, Phosphate, and dry weather flow limits.

Environment Agency (ID1270) Table 6-3 numbers are based on Thames Water estimates. However if these are not deemed as representative as those figures provided by the council, they could be moved to an appendix to avoid confusion.

Environment Agency (ID1270) Are the unnamed watercourses in Figure 6-12 of ‘High’ status? The colour of the layer used may be a little misleading and could be interpreted to represent WFD status.

Environment Agency (ID1270) The report (section 6.5.7) refers to a detailed WCS. We advise this is referenced as a phase 2 outline WCS, as done previously in the report.


Murphy (ID651) Water pressure in Hayley Green not high (can be difficult to use hose pipe). Question how the capacity judged is adequate to supply more homes.


None received.

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Comments of evidence base: CLP/Ev/4d: Bracknell Forest Local Plan – Approach to Transport Modelling (BFC, January 2018)

CLP/Ev/4d: Bracknell Forest Local Plan – Approach to Transport Modelling (BFC, January 2018)





None received.


Gaw (ID1389) Traffic model comes from 2006/07 data with some updating in 2013. Critical that actual data is used, and is crucial as projections incorporate 2026 and beyond.


None received.

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Comments of evidence base: LP/Ev/4e: Bracknell Forest Local Plan, Infrastructure Delivery Plan 2017 (BFC, December 2017)

LP/Ev/4e: Bracknell Forest Local Plan, Infrastructure Delivery Plan 2017 (BFC, December 2017)

Also see comments on specific sites, and Section 8 of the Plan.




Environment Agency (ID1270) Table 10 suggests Bracknell and Ascot sewage treatment work (STW) are most suitable to accommodate future growth requirements. This is misleading as the Water Cycle Study (WCS) indicates Ascot STW likely requires upgrades and there are potentially major constraints accommodating flow. Ascot STW exceeded its dry weather flow permit limit in 2015 prior to the proposed growth. Its suitability to accommodate proposed growth is currently questionable.

Environment Agency (ID1270) Table 10 recommends developers demonstrate adequate capacity on/off site to serve the development. This is sensible. Recommend Policy LP9 reflects this, requiring developers to provide a Foul and Surface water Drainage Strategy at planning application stage at the latest, setting out planned drainage from the site, capacity considerations, and evidence of communication with Thames Water regarding the capacity of the network and STW to accommodate the flows.

This allows appropriate lead in time for Thames Water to construct required capacity upgrades on their network or at the works. WCS table 10-1 provides indicative upgrade lead in times. Decisions on granting permission should take this into account. An approach to capacity constraints based on phasing development and mitigation is recommended in paragraphs 5 and 20 of the Water supply, wastewater and water quality National Planning Practice Guidance (NPPG). This requirement could also be included in the IDP delivery schedules (section 4, waste water sections, point 2, column 2). A key risk associated with wastewater is WFD compliance/WQ impact. This should be added to column 3 of table.

Environment Agency (ID1270) IDP delivery schedule suggests there is unlikely to be network capacity to support demand from Cluster 5. RAG assessment has flagged foul network capacity as ‘Red’ meaning upgrades will be required and major constraints identified. The delivery schedule doesn’t necessarily recognise this.

Environment Agency (ID1270) The general infrastructure delivery schedule identifies Thames Water and developers as responsible for waste water. However responsibility also falls to Local Authorities to oversee feasibility of plans and allocated sites and its time frames in line with available capacity. This mirrors the WCS (table 10.2) that Local Authorities explore options to phase delivery of local plan sites. Capacity needs to be in place prior to occupation of developments. In some cases this may require phasing of growth, ensuring capacity is provided in time. Useful to provide more information on upgrades required and timeframes for provision of upgrades.

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Environment Agency (ID1270) Rivers are not mentioned in the Green and Blue infrastructure in Section 2.1. Also not included in Section 3.0.4, Table 4 and the need to protect them or the benefits provided. Section 3.0.10 could mention the potential wastewater impact on blue infrastructure and the need for provision to stop pollution incidents and prevent WFD status deterioration.

Education & Skills Funding Welcomes Table 3 of the IDP to the responsibility of a development Agency (ESFA) (ID816) to meet its needs, in particular new schools on some of the major

sites.

The next iteration of the IDP should clearly set out how the forecast housing growth at allocated sites has been translated (via an evidence based pupil yield calculation (into an identified need for specific number of school places and new schools over the plan period.)

New schools proposed within site allocations should be clearly identified and costed. This would help to demonstrate that the approach to the planning and delivery of education infrastructure is justified based on proportionate evidence.

Sport England (ID1043) Document is not specific about what is required to meet the current and future demand for indoor and outdoors sports facilities in the local area. A Playing Pitch Strategy has been undertaken, but how the Council will look to address the needs identified in the work should be included in supporting documents.

Page. 26 relates to built sports infrastructure and indicates that improvements/development for built sports will have to be funded directly through CIL and no contributions/in-kind provision can be provided via section 106 agreements. It then goes on to explain other items such as transport may be prioritised over these facilities. Sport England is concerned that the Council is not adequately planning to meet sporting needs for the Borough.


Why is the housing mix shown in section 13.5 – Housing Mix at Table 6 totally different to the Housing mix shown in the Infrastructure Delivery Plan (IDP) at 2.3 Assumptions 2.3.1 Table 1?

(also summarised in section relating to Policy LP25).


Murphy (ID650) Gives only provisional indications of alternative transport opportunities for Policy LP7 at Hayley Green. Considered unlikely to reduce car use. No new facilities/ services aside from disproportionately large school. Comments also summarised under LP7.

Murphy (ID650) Many potential infrastructure elements marked as “none identified”. The IDP sums up that the BFLP is about building houses but almost nothing else – with primary schools to fulfil borough-wide predictions allocated irrespective of local need.

Murphy (ID650) Several comments in relation to IDP for Policy LP7. Summarised

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under LP7: topics covered: local road network, footpaths and cycleways, public transport, early years, primary school, SANG, biodiversity, green corridors, flood management, community centre infrastructure, wastewater.

Murphy (ID650) Questions where Secondary School will be located. Murphy (ID650) Biodiversity under LP7 – add oak trees and grassland to text after

‘ecologically rich’. Gaw (ID1389) Scant evidence that viability assessments have been used as tool to

assist in the development of the Draft Plan. Gaw (ID1389) Cluster 5.

Specific issues relating to footpaths and highways do not make clear where improvements will be made (e.g. application 14/01333/OUT details lack of suitable footpath/cycle options).

Oversubscription of community facilities necessitates the need for community centre capacity improvements.

Lack of health provision (GP practice) in the ward of Winkfield and Cranbourne.

Siting of two primary schools (clusters 5 and 7) in addition to existing primary school gives rise to fundamental based criteria in terms of demand.

Secondary school provision identified, but no location evidenced. Gaw (ID1389) Cluster 7.

Infrastructure at Hayley Green is limited and does not meet current needs – changing this would be costly and could affect delivery and affordability.

Allocation of a primary school does not reflect housing allocation output.


Quod of behalf of Legal & General Homes Communities (Crowthorne) Limited (ID1352)

The Draft IDP includes a number of references where it proposed that the former TRL site will help to meet the infrastructure requirements of other allocated sites:

• Land at the Hideout and Beaufort Park, Nine Mile Ride – needs to be supported by an on-site in-kind multifunctional community hub or an accessible off-site multi-functional community hub. The latter is explained as being likely to be the hub to be constructed at the TRL Site (page 47).

• Land at Broadmoor Hospital – in respect of early years education, this development is expected to include a new extended daycare centre. Otherwise, contributions towards an early years’ element in the new community hub at the TRL Site will be sought (page 152).

• Land at Broadmoor Hospital – in respect of primary

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education, the Draft IDP states that a financial contribution towards equivalent of 0.63FE additional primary school and nursery places is to be provided at either Wildmoor Heath Primary School or on the TRL development (page 153).

• Land at Broadmoor Hospital – in respect of community facilities, the Draft IDP states off-site in-kind provision at a community facility, or financial contributions towards the new multi-functional community hub on land at TRL (page 154.)

L&G wish to ensure that any such reliance on the former TRL site is discussed and agreed at an early stage, and if appropriate, necessary financial contributions are identified to secure this.

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Comments of evidence base: LP/Ev/4f: Draft Transport Accessibility Assessment of Potential Sites (BFC, February 2018)

LP/Ev/4f: Draft Transport Accessibility Assessment of Potential Sites (BFC, February 2018)





None received.


Griffiths (ID81), Gaw (ID1389) Does not agree with there being no congestion hot spots near Cluster 5. Have witnessed accidents on the Braziers Lane cross roads. Forest Road is extremely busy. Queues on Locks Ride are frequent. Very little public transport.

Vinson (ID187) Does not agree with there being no congestion hot spots near Cluster 5, significant queues especially during peak times at the Locks Ride/Forest Road/Braziers Lane junction, and also queuing back along Forest Road from the Hatchet Lane junction in North Ascot.

Brett (ID188, 189, 196, 197, 198)

Documents written by someone without first hand knowledge, such as cluster 5 having no congestion, has the area been visited? Cycle paths on roads, tiny footpaths not wide enough for two adults to walk side by side, known rat run.

Murphy (ID650, 651) Section 6, Table 10: Cluster 7 is ranked in the bottom group for accessibility, with a score of 0; no other site in this bottom group is allocated. Comments also summarised under LP7.

Murphy (ID651) Question if the cumulative impacts of previous allocations (i.e. SA9) and proposed allocations in BFLP is based on robust evidence in relation to Forest Road (queries Forest Road not being a hotspot). How robust is modelling to show that Forest Road will cope with all the additional traffic?

Murphy (ID651) Comments about footways/ cycleways/ shared paths, and improvements to public transport (indicated in IDP as potential). Refers to Draft SA scores for SA17 suggesting car will predominate. Summarised fully under Site LP7.

Murphy (ID651) Hotspots – what traffic counts have been done and when to inform the view of no hotspots in relation to Forest Road (at LP7)?

Gaw (ID1389) Housing background paper refers to ‘no traffic hotspots near Hayley Green’, but Forest Road is heavily utilised, with substantial increase in traffic from LP6 and LP7 plus other developments such as Woodhurst park.


None received.

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Comments of evidence base: CLP/Ev/5a: Landscape Character Assessment (LCA) (LUC, September 2015)

CLP/Ev/5a: Landscape Character Assessment (LCA) (LUC, September 2015)




None received.


Murphy (ID650) Remit of re-examining Entec 2006 strategic gaps means north of Forest Road not considered. No recommendations on potential gaps north of Forest Road – no policy guidance. Could feasibly abstract from guidance available, i.e. North Ascot-Bracknell gap interpreted partially on the Policies Map in the designation of an expanded Hayley Green Woods as a Local Nature Reserve, which now extends from Winkfield Row to Westmorland Park, and in the small Local Nature Reserve on the Bull Brook corridor.


None received.

461

Comments of evidence base: CLP/Ev/5b: Landscape Recommendations Report (LUC, September 2015)

CLP/Ev/5b: Landscape Recommendations Report (LUC, September 2015)

Also see comments on Gap Policy.




Murphy (ID651) Remit of the study did not look at proposed new allocations, so there are no recommendations or policy guidance for sites like LP7 where development is now proposed north of Forest Road. This should ideally be reviewed. Comment included under site LP7.

462

Comments of evidence base: CLP/Ev/5c: Green Belt Review (Amec, June 2015)

CLP/Ev/5c: Green Belt Review (Amec, June 2015)


463

Comments of evidence base: LP/Ev/5d: Green Belt Village Assessment (BFC, February 2018)

LP/Ev/5d: Green Belt Village Assessment (BFC, February 2018)


464

Comments of evidence base: LP/Ev/5e: Landscape Sensitivity Appraisal of Potential Housing and Employment Sites in Bracknell Forest (LUC, February 2018)

LP/Ev/5e: Landscape Sensitivity Appraisal of Potential Housing and Employment Sites in Bracknell Forest (LUC, February 2018)





None received.


Murphy (ID651) Detailed comments about the consistency of the Housing Background Paper and Landscape Sensitivity Appraisal in relation to LP7. Summarised under LP7.

Murphy (ID651) Disagrees with some text in ‘Landscape Character’ section (p.304):

“To the west the perceptual character of the cluster is influenced by its position adjacent to the linear residential development extending along Hayley Green (road).” Cites reasons including land to north of current defined settlement, much of Hayley Green Road is bordered by fields, buildings are farm buildings. Has same ‘quiet rural character’ referred to as valued features in WAR13, WAR15 and WAR16.

“To the east along Cricketers Lane the landscape character has a quiet rural character typical of the wider clay farmland.” Cites reasons including aside from southwest/ northwest corner, character detracted from by hedges around large properties, pub and associated car park/ garden, maintained boundary treatments giving ‘groomed appearance’, school fields/ grounds not typical of ‘wider clay farmland’.

Later sections indicate distinctions in rural character not as clear. Valued features in WAR13, WAR15 and WAR16 are same; rural lanes in WAR13 and WAR16 treated same, but cluster treated differently. Therefore extra sensitivity applied to Cricketers Lane (WAR16) may have been amplified.

Murphy (ID651) Questions historic link with Brockdale referred to under WAR16, especially as not referred to in Draft Historic Environment Assessment of SHELAA sites. Link has bearing on sensitivity on site as part of LP7, association should be explained and referenced.

Murphy (ID651) ‘Landscape character’ section for WAR16 of medium-high not consistent with Draft Historic Environment Assessment of the site. Also pub thrives and is busy. Cricket club is actually school playing fields, currently marked out for rugby. Whilst pleasant area, Landscape sensitivity attached to WAR16 merits reconsideration.

Murphy (ID651) Smaller field attributes of WAR16 are applied in many instances to the whole site, adding to inaccuracy. Little said about larger field. Contributes to statement ‘eastern edge located in more rural area’

465

Comments of evidence base: LP/Ev/5e: Landscape Sensitivity Appraisal of Potential Housing and Employment Sites in Bracknell Forest (LUC, February 2018)



which should be reviewed in light of inconsistencies highlighted and Housing Background Paper: Basis of Allocation.

Murphy (ID651) Low landscape sensitivity of WAR13 difficult to understand. Cites descriptions including oak trees in fields and hedgerows, and area described as relatively tranquil.

Murphy (ID651) WAR15 previously rubble-strewn field, current landscape status reward for landowner efforts. Represents what could be achieved across whole site and reminder of what is to be lost if LP7 goes ahead.

Murphy (ID651) WAR22 was not assessed individually. Less weight can therefore be attached to its sensitivity ranking. It is boarded by housing, but a very pleasant rural field like WAR13.



466

Comments of evidence base: CLP/Ev/6: Design SPD

CLP/Ev/6: Design SPD


NB: The Design SPD was subject to a specific consultation prior to its adoption in March 2017.

467

Comments of evidence base: CLP/Ev/7a: Archaeological Appraisal of Sites (Berkshire Archaeology, April 2017)

CLP/Ev/7a: Archaeological Appraisal of Sites (Berkshire Archaeology, April 2017)


468

Comments of evidence base: LP/Ev/7b: Historic Environment Assessment of Sites (LUC, February 2018)

LP/Ev/7b: Historic Environment Assessment of Sites (LUC, February 2018)





Murphy (ID651) Informative and realistic in relation to Hayley Green Farm. Does not dispute conclusion of ‘no substantial harm’ to Moathouse and Hayley Green Farm. Welcomes reference to school sites (WAR16) and the milestone so significance is highlighted.

Murphy (ID651) Correction suggested: need to capture there are two Grade II listed buildings and moat (non-designated). Moathouse and separate barn. Information feeds into other evidence documents which are confusing buildings.

Murphy (ID651) Evidence in relation to WAR16 should be reviewed to ensure consistency with Landscape Sensitivity Appraisal subsection about historical context (p.174 and 175). No mention of Brockdale in the HEA of Sites. Landscape Sensitivity Appraisal assigns greater impact on Brockdale than this document. Feeds into other documents.

Murphy (ID651) Suggested amendment to Cluster 7 page 240: WAR13 add reference to historic hedge boundaries. Been there since C19th OS map. As currently reads could be interpreted as being relatively devoid of historic features. Wooded shelterbelts at Warfield House (point of interest) shown on old OS maps from 1856 onwards.

469

Comments of evidence base: CLP/Ev/8a: Ecology Surveys (John Wenman Ecological Consultancy, September, 2017)

CLP/Ev/8a: Ecology Surveys (John Wenman Ecological Consultancy, September, 2017)





Murphy (ID651) Table 2.1 – no mention of woodland and trees under ‘protected/ notable species’ despite BFC commitment. Trees ranked in terms of other species they might support rather than for intrinsic value.

Murphy (ID651) Anecdotal evidence of badger sightings on Bracknell Road near WAR13. (Table 2.1).

Murphy (ID651) Concern over use of ‘potential’ informing site rankings for Great Crested Newts. Unclear why not definitively confirmed using DNA-based tools. Consider where rankings in Table 2.1 are potential should carry little/ no weight e.g. WAR15.

Murphy (ID651) Table 2.2 – Stag Beetle sighting recorded in at least one garden near WAR13.

Murphy (ID651) Inconsistency with approach to WAR15 ‘features of local importance’ Table 2.2 on conditional tense, compared to WAR13, e.g. badgers ‘likelihood’ versus ‘potential’ in WAR13 Table 1.1. Also refers to plants/ habitats requiring further survey, and Reptiles / Great Crested Newts (GCN) ‘could offer suitable habitat’ although elsewhere state no GCN been recorded with 1km. Insufficient evidence to inform ranking or decisions for WAR15 at this stage. Also potential for GCN highlighted (low ranking) in WAR16 and WAR22 despite caveats on lack of records, unclear why. But in WAR13 evidence judged sufficient to discount potential for GCN.

Murphy (ID651) Para. 2.2.4 & Figure 1 – does not accurately reflect evidence presented in tables. Disagree with basing ecological analysis on land ownership/ site boundaries, e.g. small segment of WAR13 interposed between WAR15 and WAR16. Rankings based mostly on potential. Absence of evidence on some features results in no inclusion on figure (e.g. intrinsic value of trees WAR13) and in other circumstances been included and presumably informed ranking despite absence of evidence (e.g. grassland WAR15 and WAR22 – need for more data but assigned moderate rank based only on potential). WAR16 and WAR22 described as poor (ranked low) but no supporting information is given on grassland in these sites. No description given for WAR13 grassland either - ranked ‘negligible’. Different treatment of sites queried.

Murphy (ID651) Unclear how hedgerows in Table 2.2 can be determined to be poor species when no information is given on species composition. Verges around parts of cluster seem species rich – would like to see them assessed and marked to protect during development. Supportive of highest rank assigned in Cluster 7 (moderate).

Murphy (ID651) Unclear why oak trees in WAR13 are indistinguishable (yellow circles (low ranking)) – potential for roosts bats/ birds, but also have intrinsic ecological value. Should have larger circumference than bole of tree. Also trees definitely present on site, but other features get higher ranking on the basis something might potentially be there

470

Comments of evidence base: CLP/Ev/8a: Ecology Surveys (John Wenman Ecological Consultancy, September, 2017)



(WAR15 grassland) or Great Crested Newts. Housing Background Paper refers to replacing woodland in WAR15 that may have been absent for centuries in that site, so should protect these existing oak trees.

Murphy (ID651) WAR13 buildings marked ‘low potential’ for roosting bats but tress in fields and in southeast corner of WAR22 marked ‘potential’. No text in Table 2.1 to explain difference. States bats are seen in gardens adjacent WAR13.

Murphy (ID651) Rankings do not seem to match evidence. WAR13 alone in having ‘negligible’ ranking, but strongly represented in Table 2.1 more so than most other sites as indicating range of species / habitats. Compares well to all other sites in Cluster 7. In Table 2.3 WAR13 hedgerow/grassland/woodland habitats opportunities for ecological enhancement, but have oak trees definitely been there? WAR15 ‘moderate’ based on potential grassland alone. WAR16 (field) and WAR22 (apart from patch of woodland) ranked ‘low’ based on potential for GCN (despite no records within 1km) and grassland (despite no evidence in tables except marginal grassland).

471

Comments of evidence base: LP/Ev/8b: Ecology Surveys – Addendum Report (John Wenman Ecological Consultancy, February 2018)

LP/Ev/8b: Ecology Surveys – Addendum Report (John Wenman Ecological Consultancy, February 2018)





Murphy (ID785) Para. 2.1.1 - Data presented and conclusions for cluster 7 are in places confusing and frequently subjective.

Murphy (ID785) Table 2.1 (in relation to Cluster 7) – rows: ‘Common reptile species’ – grass snakes in area so ‘low’ it is misleading. ‘Lowland Meadow’ – question ranking of low given assessment not been completed. ‘Nesting birds’ – question what ‘commonly occurring birds’ means? Why just nesting birds? WAR13 has trees/hedgerows/ rich agricultural land with Fieldfares and Regwings in winter. Species are on Schedule 1 of Wildlife and Countryside Act 1981. Resident species present in Cluster 7 also listed in NERC Act. Also references other species present in Cluster 7: Hare, Tawny Owl, Red Kites, Sparrow Hawk, Heron, Moorhen, other songbirds. Invertebrates – butterflies, moths, beetles (including Stag Beetle).

Murphy (ID785) Table 2.2 (in relation to Cluster 7) – rows: 1st row – Stag Beetles have been recorded next to WAR13 4th row – Badgers are present. Sighting of live badgers near WAR13 & adult killed on Bracknell Road Feb 2018.

Murphy (ID785) Table 2.3 (in relation to Cluster 7): 2nd row – hedgerows. Poor diversity due to poor management in past. Reference to historic OS maps showing them.

Murphy (ID785) Opportunities for ecological enhancements in Cluster 7 treats site like island not linked to surrounding area. Cluster 7 important bridge between Hayley Green Woods and wider Green Belt to the north. Most species have very fluid ranges and depend on wide area for survival. Conservation of ecological assets important for Cluster 7 and the wider area.

Murphy (ID785) Summary map of ecological constraints/ mitigation – ranks of constraint make no sense and are subjective.

Question why WAR13 is ‘negligible level of constraint’. Has rich soil and surrounded by ancient hedges and some veteran trees. Grassland ‘as it is’ due to grazing, if left like WAR15 would develop rich flora as field is frequently wet, so would be lowland meadow rank. Criteria used for WAR22 as ‘low level constraint’ is unclear. No obvious difference to WAR13. Unclear why hedgerows in west side of Cluster 7 are marked poor. No assessment data presented. Considered pointless and misleading to rank WAR15 and WAR16 as ‘negligible level of constraint’ ranking due to such a small area with frequent local species movements.

472

Comments of evidence base: CLP/Ev/9a: Green Infrastructure Review (TVERC, September 2017)

CLP/Ev/9a: Green Infrastructure Review (TVERC, September 2017)



Murphy (ID628) GI evidence base is incomplete. Defining settlement boundaries without it is premature and could be detrimental to final site design/planning stages.

Murphy (ID651) Excellent to be able to see this document available to view. Murphy (ID651) WAR13, WAR15, WAR16 (&WAR22) identified as grassland

network – only WAR16 identified as significant for grassland GI. Questions connections of site. WAR13 and WAR15 seem more significant but with WAR16 could form ‘bigger, better, better-connected’ grassland GI.

Murphy (ID651) WAR13, WAR15 & WAR16 in woodland network but none as significant for woodland connectivity. Could change if hedgerows factored in, also individual oak trees. Reference to old OS maps. General wooded area and large oak trees of WAR13 seem valuable in GI terms, especially with hedgerows.

473

Comments of evidence base: LP/Ev/9b: Level 1 Strategic Flood Risk Assessment (SFRA) (JBA Consulting, February 2018)

LP/Ev/9b: Level 1 Strategic Flood Risk Assessment (SFRA) (JBA Consulting, February 2018)




Environment Agency (ID1270) Generally supportive of assessment and its findings. Pleased amendments made following previous comments.

Like to see some minor amendments to Map 4, which is not very clear. In areas where modelling is available, Flood Zone 3a 70% climate change is layered above other flood zones, making it hard to interpret. Then, in areas where there is no detailed modelling, Flood Zone 3a and Flood Zone 2 only are shown.

This SFRA states that Flood Zone 3 in areas with no detailed modelling will be considered as Flood Zone 3b and the map should reflect this to avoid confusion


Murphy (ID628) Flooding evidence base is incomplete. Defining settlement boundaries without it is premature and could be detrimental to final site design/planning stages.

Murphy (ID651) Error in Stage 1 SFRA: WAR16 not included. WAR22 named ‘Land to the rear of Cricketers, Cricketers Lane’ - but this name applies to WAR16. Unclear whether data should be assigned to a new entry WAR16 and new data generated for WAR22, or if just simply name of site of WAR22 that is wrong.


None received.

474

Comments of evidence base: CLP/Ev/9c: Draft Sequential Test (BFC, February 2018)

CLP/Ev/9c: Draft Sequential Test (BFC, February 2018)




None received.


Murphy (ID651) Error in Stage 1 SFRA: WAR16 not included. WAR22 named ‘Land to the rear of Cricketers, Cricketers Lane’ - but this name applies to WAR16. Unclear whether data should be assigned to a new entry WAR16 and new data generated for WAR22, or if just simply name of site of WAR22 that is wrong.


None received.

475

Comments of evidence base: CLP/Ev/10a: Duty to Co-operate Framework

CLP/Ev/10a: Duty to Co-operate Framework

None received.

NB: this document was subject to consultation prior to publication in February 2016.

476

Comments of evidence base: CLP/Ev/10b: Regulation 18 Consultation Statement (Scope of the CLP)

CLP/Ev/10b: Regulation 18 Consultation Statement (Scope of the CLP)

None received.

NB: this document was subject to consultation prior to publication in February 2016.

477

Comments of evidence base: CLP/Ev/10c: Site Selection Methodology (BFC, June 2017)

CLP/Ev/10c: Site Selection Methodology (BFC, June 2017)

None received.

NB: this was subject consultation prior to its publication in June 2017.

478

Comments of evidence base: CLP/Ev/10d: Strategic Housing and Economic Land Availability Assessment (SHELAA), Part 1: Methodology (BFC, June 2017)

CLP/Ev/10d: Strategic Housing and Economic Land Availability Assessment (SHELAA), Part 1: Methodology (BFC, June 2017)

None received.

NB: this was subject consultation prior to its publication in June 2017.

479

Comments of evidence base: CLP/Ev/10e: Strategic Housing and Economic Land Availability Assessment (SHELAA), Viability Assessment (BNP Paribas Real Estate, June 2017)

CLP/Ev/10e: Strategic Housing and Economic Land Availability Assessment(SHELAA), Viability Assessment (BNP Paribas Real Estate, June 2017)

See comments on specific sites, together with comments on specific sections of the Plan, such as housing policies, and internal space standards.





NPPF Paras 173 and 177 specify that local plans should be viable and deliverable. No evidence of viability assessments being used as a tool in assisting the development of the Draft LP.

480

Comments of evidence base: CLP/Ev/10g: Draft Habitats Regulations Assessment (HRA) (BFC, January 2018)

CLP/Ev/10g: Draft Habitats Regulations Assessment (HRA) (BFC, January 2018)




Natural England (ID112) The HRA does not adequately cover the potential issue of air pollution around European designated sites (such as Thames Basin Heaths SPA, Windsor Great Park SAC and potentially other European sites outside of the administrative area), either alone or in-combination with other Local Plans in the area. (Noted that the Council recognises that there is still work to be undertaken to establish air quality effects on European Sites and that they propose to undertake strategic traffic modelling). Natural England would be happy to advise and comment on the air quality assessment during the draft stages.

Table 4.2 - there wouldn’t necessarily be a likely significant effect on the Thames Basin Heaths SPA as a result of the provision of car parking spaces within the 400m zone. It is the accessibility of these car parking spaces to the general public that would instigate a potential likely significant effect. We could rule out likely significant effect with regard to this characteristic if these spaces were for private use only and fully secured using measures such as barriers/security personnel etc. so that the general public were unable to access them for recreation purposes.


Murphy (ID651) Warfield/ Winkfield have long-distance commuters and given scale of already allocated and proposed development, impact on European sites should be factored in at an early stage.

Murphy (ID651, 652) Further assessment should include in-combination assessment of entire BLP, including SALP, and be in conjunction with other BFC and LA relevant plans – for deposition impacts on Windsor Forest & Great Park SAC and TBH SPA.

Murphy (ID651) Questions if acceptable to develop fields in heart of Hayley Green (LP7) and mitigate this with contributions to off-site SANG c. 1.5 miles away. Location would increase car use.

Murphy (ID652) Para. 1.16 & 1.17. Ref to emails from BFC and FOI request. It seems that the SALP allocations were not screened against the Windsor SAC for N deposition.

• 2007 screening exercise for the Core Strategy did not include air pollution (the SALP did). Windsor SAC was screened out in the CS process.

• NE requested the Windsor SAC to be screened in response to the SADPD consultation, but cant find evidence of this is SAL33, and NE signed it off.

• If correct SAL33 screened all SALP sites for potential impacts including air pollution against the TBH SPA, but not the Windsor SAC.

• The BFLP draft HRA screens new allocations for potential impacts including air pollution on both European sites, but

481

Comments of evidence base: CLP/Ev/10g: Draft Habitats Regulations Assessment (HRA) (BFC, January 2018)



does not assess carried forward SALP sites. • Conclude that no SALP allocations have ever been screened

for air pollution impacts against Windsor SAC as this was screened out in 2007.

Murphy (ID652) Table 3.2, page 19. Policies LP4, LP5, LP6 & LP7 are scored no for recreational impact on the SPA. LP3 is scored yes, should they all be yes?

Murphy (ID652) Para. 2.6.a) Does this mean that if a site is below the mitigation threshold (e.g. TRL - 0.5% increase in N deposition estimated) it continues to be screened out? (b) If a site were to need mitigation, how would its contribution be estimated over time, i.e. how would one know whether it was still contributing to a loss of site integrity or not?

Murphy (ID652) Para. 2.8. Does not seem to reflect the Wealden/Lewes judgement Murphy (ID652) Table 2.1. Seems a short list of authorities, will more be added? Murphy (ID652) Para. 3.17. Regarding BFC projects/plans 2017-2034 with potential

to impact upon European sites, will unbuilt SALP allocations that are being incorporated in to the BFLP be included in the assessment.

Murphy (ID652) Para. 3.22. The Housing background paper collates information for each site and evidence base is used to inform the sustainability appraisals, but no relevant HRA information has been included in the process.

Murphy (ID652) Para. 4.22. Avoidance should be the first preference i.e. not allocate sites identified to potentially have an impact. Both European sites are well above minimum critical load per year. Under these circumstances, BFC and other relevant LAs should be looking at mitigation measures to reduce the already unacceptably high N deposition levels, and avoiding wherever possible additional activities/projects with potential impact, e.g. large developments producing relevant traffic.

Murphy (ID652) Paras. 4.23-4.25. In light of above, will any weight be put on the HRA when deciding final allocations?

RSPB (ID1229) Notes that the Draft Habitats Regulations Assessments recognises the potential for significant air quality effects upon the SPA and SAC as a result of the proposed allocations./policies. Acknowledge that further assessment is on-going and will form part of the submission stage, and will review the assessment at that stage.


None received.

482

Comments of evidence base: CLP/Ev/10h: Strategic Housing and Economic Land Availability Assessment (SHELAA), Part 2: Results (BFC, December 2017)

CLP/Ev/10h: Strategic Housing and Economic Land Availability Assessment (SHELAA), Part 2: Results (BFC, December 2017)

None received.

NB: this document as subject to separate consultation prior to its publication in December 2017.

483

Comments of evidence base: missing evidence base

Other: Missing evidence base




None received.


Murphy (ID628) No evidence document explaining the strategy for distribution of new primary schools. Queries allocating two 2-form entry primary schools with a mile of each other at edge of Bracknell. Policy LP7 does not trigger need for even one primary school. IDP (pa. 68, column 3) developers elsewhere could contribute to a second-form entry; school will accommodate children from elsewhere. Traffic & associated sustainability issues. Contrary to LP1 and LP45.

Murphy (ID628) Biodiversity evidence base is incomplete. Defining settlement boundaries without it is premature and could be detrimental to final site design/planning stages.


None received.

484