BOROUGH LOCAL PLAN CONSULTATION 2016
FORMAL COMPLAINT BY
THE OAKLEY GREEN & FIFIELD RESIDENTS ASSOCIATION
The Oakley Green and Fifield Residents Association (OGFRA) wish to register their dissatisfaction with the Borough Local Plan (BLP) Consultation which ran from 02 December 2016 to 13 January 2017, both in terms of ‘process’; the way the consultation was conducted and it’s ‘content’; proposals to develop large swathes of Green Belt, in conflict with Government advice, in particular the area referred to as HA11, on both sides of the A308 on the edge of Windsor.
We consider the consultation process was seriously flawed. It was unfair, undemocratic and failed to provide RBWM’s residents with an equal opportunity to register their comments, for the following reasons:
- Publicity for the Consultation was completely inadequate. The Borough did the minimum required to advise residents of the Consultation and how to respond. A very large number of residents were totally unaware of the Consultation until they received OGFRA’s email and/ or flyers delivered by ourselves or the Parish Council.
- There was much anger at the Consultation taking place over the holiday period of Christmas and New Year, leaving inadequate time for residents to review the extensive documentation published by the Borough. The Consultation period ran for the statutory minimum period of 6 weeks, which given that this included public holidays when residents could be expected to be away from home or otherwise engaged, should have been extended, as has happened in the past. The community could not understand the Borough’s hurry and outright refusal to extend the Consultation period.
- The Consultation Portal encouraging residents to respond on-line was not user-friendly in any way. Competent computer users found it confusing and unclear, and this undoubtedly deterred residents from responding. It could even be considered to be discriminatory in that all residents would not have an equal opportunity to respond.
An analyst’s comments are attached.
- Some details of the sites being put forward for development were incorrect. This was particularly true of HA11, which included land that the current owners had not agreed could be developed.
- From the above, we consider that, collectively, this amounts to a failure to comply with requirements contained within RBWM’s Statement of Community involvement
We urge the Borough therefore to:
- give residents (and all other stakeholders) another opportunity to comment further on the updated draft Borough Local Plan during the Regulation 19 consultation given the deficiencies in the Regulation 18 consultation;
- publish the Infrastructure Delivery Plan (and other key ‘missing’ documents) at the earliest opportunity to give adequate time for scrutiny i.e. before April if possible.
Proposals within the Draft BLP to develop large swathes of Green belt, particularly in Bray Parish, are in conflict with Government guidance in relation to development of the Green Belt. In accordance with the National Planning Policy Framework there is no case for altering the adopted Green Belt boundary unless exceptional circumstances are found to exist. The Plan places a disproportionate load on Bray Parish in terms of proposed dwellings in an area that is 94.8% Green Belt.
Area HA11, on both sides of the A308 on the edge of Windsor, contributes significantly to the ‘Green gap’ between Windsor and Maidenhead, therefore any development of this stretch of Green belt would represent serious erosion of the Green belt and contribute to urban sprawl.
In addition to this fact, there are compelling reasons relating to infrastructure, and impact on the local environment, stretching into central Windsor and beyond, for not developing this area.
- The allocation of HA11 for development takes no account of the Bray Parish Neighbourhood Plan (’BPNP’) and proposed ‘Bray Green Gap’. Bray Parish Council formally submitted the BPNP to the Borough in November 2016 after over 5 years of meetings, consultations etc, many involving the Borough. Bray Parish residents strongly wish to maintain the separate physical locations and identities of the towns of Windsor and Maidenhead, preserve the rural identity of Bray Parish and halt any further encroachment on the remaining Green Belt between the outskirts of Windsor and Maidenhead. For this reason the BPNP seeks to designate the land between Windsor and Maidenhead as a permanent ‘Bray Green Gap’ (see Map 3 in ‘Final for Submission’ version of BPNP dated September 2016). This map demonstrates that HA11 lies in its entirety within the Bray Green Gap and the inclusion of HA11 as a development site is in direct contradiction to the intent of the BPNP. Whilst the BPNP has not been adopted yet, it indicates clearly the intent of local residents, and it makes a mockery of the principles of Localism to put forward this site.
- HA11 should not be removed from the Green Belt. In accordance with the National Planning Policy Framework there is no case for altering the adopted Green Belt boundary unless exceptional circumstances are found to exist through the Borough Local Plan process. We do not consider that any such ‘exceptional circumstances’ exist in the case of HA11 and that the Edge of Settlement analysis does not correctly reflect the importance of HA11 (referred to as W1 and W2 in the Edge of Settlement analysis):
- contribution to preventing merger of settlements is classified as ‘moderate’. This can only be classified as ‘very strong’. HA11 occupies a significant portion of the gap between Windsor and Maidenhead and is an essential component of the Bray Green Gap set out in the BPNP for the reasons stated above;
- contribution to preventing urban sprawl and encroachment into the countryside are only listed as ‘moderate’. We consider that the contribution is ‘strong’ or ‘very strong’. The impact of developing W1 and W2 is no different to that of developing W3, W4 or W5 (all edge of Windsor), all of which are classified by the same assessment as ‘strong’ or ‘very strong’;
- there are other more appropriate potential sites which according to the Edge of Settlement analysis meet less than three of the Green Belt criteria.
- The use of any Green Belt land should be the very last resort and it should be planned to be developed last to allow time up to 2033 for more appropriate non-Green Belt sites to become available. This would give the Borough the best opportunity to honour its commitment (and election promises of its Members) to preserve the Green Belt.
- In addition to its contribution to the Green Belt and Green gap, Area HA11 is good quality agricultural land (Grade 3A0 therefore should not be used for development. The Sustainability Appraisal for the Borough Local Plan 2013-2033 dated November 2016 states that the top three grades of agricultural land, Grade 1, 2 and 3a, should be avoided for development (in accordance with national policy) and brownfield sites used in preference. Area HA11 has been farmed for decades, dating back to before World War II. Part of it was still actively farmed in the 1970s and 1980s, growing a variety of agricultural crops, including onions and brassicas. Land that was not used for arable farming was used for grazing livestock, as it still is today.
- It can be established by reference to the Ministry of Agriculture, Fisheries and Food report of October 1988, Agricultural Land Classification of England and Wales, based on the range of crops previously grown, the classification of at least Grade 3A should apply.
- Effect on infrastructure. The A308 is the main road connecting Windsor and Maidenhead and feeds the M4 at Junction 8/9 and also at Junction 6. There is no report on how RBWM intends to manage the additional traffic created by an extra 1,000 dwellings feeding onto this road. The A308 (and surrounding roads) are already at capacity and we face gridlock if these additional dwellings are built; and this is before considering the impact of Crossrail and a possible large hotel on Windsor racecourse.
In addition to the above, there are many other reasons why HA11 is unsuitable for development. These include:
- The site is prone to surface flooding and is unsuitable for development.
- Air pollution will increase significantly in Windsor as residents of the proposed dwellings on HA11will use their motor vehicles to access either Maidenhead, thus significantly adding to the air pollution AQMAs.
- Loss of key public amenities. The two garden centres are very important to the local community
- Detrimental impact on Cardinal Clinic, a Community Mental Health Facility.
- Heritage. The Old Farmhouse, also located to the south of HA11, is a Grade II* listed property.
- i. Adverse impact on biodiversity
Please see supporting document – Comments on the Borough Local Plan Consultation 2016, for further detail on these points.
HA11 should not therefore be put forward for development and should be removed (as have some areas previously included in the consultation with a similar profile including agricultural).
- POLITICAL CONTEXT
Alternative sites should be considered. In addition to reviewing the Edge of Settlement analysis we believe that the Borough should reassess potential sites in the Borough and:
- consider previously developed land that has not yet been assessed, but is likely to become available in the future e.g. Broom Farm Estate (where many properties are empty), possible closure of Combermere barracks;
- examine the use of empty dwellings;
- consider additional dwellings (where possible) for those sites already with planning permission.
- We are informed by Borough Councillors that proposals for new sites are ‘emerging’ all the time, therefore there is no need for the Borough to panic into proposing a full 100% quota at this stage. The quota will be filled as time progresses to 2033.
There is no requirement to meet the Objectively Assessed Need. Whilst acknowledging the need for new housing throughout the country, our view is that the Borough should submit a Plan that does not fully meet the objectively assessed need for housing. Planning Guidance recognises constraints, such as Green Belt, which may limit the ability of an LPA to meet its objectively assessed need. In the case of the Borough the high proportion of Green Belt land and Crown Land represent such constraints.
We note the comments by Gavin Barwell, Housing Minister, in relation to the Housing White Paper of 7 February 2017, that ‘there is no need to take huge tracts of land out of the Green Belt to solve the housing crisis.’
In conclusion, we object to the proposed development of site HA11 with a planned 650 dwellings and removal of this land from the Green Belt and request that this site is removed from the consultation.
On behalf of the Chairman and Committee of the Oakley Green & Fifield Residents Association