Main Modifications Consultation
It is some time since our last Update which looked at progress with the Examination of the Borough Local Plan and next steps. The Borough is currently consulting on the final proposed changes (‘Main Modifications’) to the BLP considered necessary to make the Plan sound and capable of adoption.
The consultation was launched over the summer holiday period and the deadline for comments is just under a week away at midnight Sunday 5 September. OGFRA remains concerned over a number of aspects of the Plan – in particular failure to address capacity and other issues on the A308. This could be the last opportunity for residents to comment on the Plan and we urge all concerned residents to make their views known.
- Consultation details. The full suite of Main Modification consultation documents can be found at https://www.rbwm.gov.uk/home/planning/planning-policy/emerging-plans-and-policies/draft-borough-local-plan/examination-local-plan/consultation-main-modifications-borough-local-plan-submission-version .
- How to respond. RBWM encourages online responses using the Consultation Portal at https://consult.rbwm.gov.uk/portal/blp/blpmm/blpmm . However many people find this rather unwieldy and you can also respond:
via email to: firstname.lastname@example.org
via post to: FREEPOST RBWM PLANNING POLICY
The Borough is only seeking comments on new elements of the Main Modifications and not matters that have previously been considered. However it is acceptable to refer to new information where appropriate.
- Issues you might raise. OGFRA has consistently argued that (a) AL21 should remain in the Green Belt and that the Council has sufficient ‘buffer’ in terms of proposed housing numbers that development of AL21 is not required and (b) that any development of AL22 would need to be at much lower density and less visually intrusive and in keeping with its setting. One of our main concerns with site allocations AL21 and AL22 has been the traffic impact on already congested local roads. However the Main Modifications do not address these concerns; the AL21 and AL22 site allocations remain and only minor changes (highlighted in yellow) have been made to the Site Allocation Proformas (copies attached).
Here are some key issues you might raise:
- the BLP still lacks detail on critical issues such as infrastructure delivery and, in particular, how the A308 could cope with the planned development along its length. The issues this road has in terms of congestion, noise and air pollution are well known but it appears that very little progress has been made with the critical A308 study part funded by central government way back in 2018. Recent developments that will further increase pressure on the A308 are: approval of the Aldi store on Green Belt land on Dedworth Road (and not contemplated under the BLP); plans for ‘permanent’ redevelopment of Bray Studios to create new film and TV studios; approval for 10 years of gravel extraction on land opposite Bray Studios (with all movements in/out by lorry); and Bracknell Forest pushing ahead with plans for 2,000 new dwellings at Jealotts Hill which will undoubtedly impact local infrastructure. This is in addition to the planned development in the BLP at AL21 (450 dwellings etc), AL22 (39 dwellings) and AL26 (100 dwellings at Bray Lake next to Thames Valley Hospice).
- it seems that RBWM intends to address the serious issues on the A308 on a piecemeal basis with developers, with Site Proformas providing for measures such as Travel Plans, appropriate public transport, car sharing etc. However such measures cannot possibly address the issues on the A308 (and feeder roads) and we consider that the the BLP cannot be viewed as sound in such circumstances.
- in responding to the various BLP consultations OGFRA has consistently argued that no further development along the A308 (including the allocated sites) should be allowed until the study has been completed and necessary capacity and air quality measures (and associated funding) have been clearly identified. We are at a loss to understand why this crucial study has not been given the priority it deserves.
- the revised Site Proformas for AL21 include ‘conserve, or preferably enhance, the Grade II* listed Old Farmhouse and its setting’ and ‘consider and avoid or, where necessary, mitigate potential disturbance impacts on users of the Cardinal Clinic’. The Aldi planning approval failed to give these protections, and it is essential that any development of AL21 pays full attention to these requirements. In addition part of the area bordering AL21 (north of the A308) has been considered worthy of conservation area status by the Borough and Bray Parish Council area and should be acknowledged as a non-designated heritage asset in the Site Proforma. Any development proposals should respect this.
OGFRA will be responding on the planning application (no. 21/02245) for the redevelopment of Bray Studios to create new film and TV studios. Note that RBWM is allowing comments up to 7 September.
A revised planning application (no. 21/02467) has been submitted for 30 dwellings on the Squires Garden Centre sites (site allocation AL22 in the draft BLP). The Neighbour Consultation Expiry Date is 23 September and we will circulate some comments on this application prior to that date.
30 August 2021