Guidance Notes for objecting to Borough Local Plan (2013-2033) Submission Version incorporating Proposed Changes, October 2019 (BLPSV-PC)
Closing date for submitting comments is midnight Sunday 15 December 2019
Further to the Regulation 19/20 consultation on the Borough Local Plan Submission Version in 2017, RBWM launched a Consultation on ‘Proposed Changes’ to the BLPSV (‘BLPSV-PC’) on 1 November which runs for 6 weeks to 15 December 2019.
Why the delay? In June 2018 the Inspector held ‘Stage 1’ hearings and raised a number of concerns. The Plan was then ‘paused’ to allow RBWM to undertake additional work to address concerns raised by the Inspector. RBWM has taken on board some of the concerns raised during the Regulation 19/20 consultation, but there are still significant issues that are of concern relating to traffic congestion, air quality, protection of the Green Belt, flooding, density of development and noise pollution.
Two thirds of the policies in the BLPSV-PC have changed, so you should look at policies that are of concern to you. Full details of the Consultation with supporting documents can be found at http://consult.rbwm.gov.uk/portal/blp/blpsv-pc/blpsv-pc-oct19 – this includes Consultation Explanation Statement and other documents under the ‘Supporting Documents’ tab.
As OGFRA our primary interest is in the area immediately around us, and we are very disappointed to see that site HA11 has both been retained and the number of houses increased. HA11 has been split into two sites (as shown overleaf):
- AL21 Land west of Windsor, north and south of the A308 (450 dwellings)
- AL22 Squire’s Garden Centre (39 dwellings)
These Guidance Notes provide information on how you may respond in relation to site allocations AL21 and AL22. Details of these sites can be found on pages 269 and 271 in the document Borough Local Plan (2013-2033) Submission Version incorporating Proposed Changes, 2019 using the above link.
What can I comment on?
On this occasion, objections should address the proposed changes, and comment on whether the changes make the BLPSV-PC sound, and legally compliant. Although resubmissions of previous comments is not encouraged, we need to impress on the Inspector that the changes have not overcome our objections.
What should my response focus on?
Your responses should focus on the following issues – Include your personal details and state that your comments relate to changes in the BLPSV–PC which fail to make the document sound and legally compliant. They relate to the housing allocations AL21 and AL22 (formerly known as HA11, land west of Windsor, north and south of the A308). Key points are:
- the housing allocation for this Green Belt land on the edge of Windsor has been increased from 450 to 489 dwellings – this will be seen as a minimum.
- OGFRA and the community has already made repeated objections. The changes now proposed do not overcome those objections, and in some cases make it worse. The key concerns are:
- loss of Green Belt – resulting in urban sprawl between towns Windsor and Maidenhead and incursion into the important ‘green gap’ between these two towns
- loss of good agricultural land – the land was actively farmed, growing a range of agricultural crops, before the ‘new’ section of the A308 was built in the 1980’s bisecting the fields
- impact on infrastructure, particularly traffic. The A308 is routinely gridlocked at peak times, leading to delays and inconvenience for local and through traffic. The Council has failed to provide evidence that it can cope with the many planned developments along the A308.
- impact on air pollution and health from standing traffic as a result of additional vehicles joining the A308 at peak times (and on surrounding roads – Dedworth Road, Ruddlesway and Oakley Green Road). Measures for environmental protection proposed in the Plan do not come close to addressing the scale of the problem.
- flood risk still not fully addressed as part of the sites are in Flood Zone 2 and 3 and concern over adequacy of sewage systems
What should I object to?
You should object stating that the Plan is still ‘unsound’ because:
- It is not positively prepared – it does not meet infrastructure requirements for such a scale of development. It is not justified. The Plan now has a buffer of around 2,000 dwellings, which should be utilised instead of embarking on development of AL21 and AL22. It is not effective or deliverable due to lack of infrastructure. Finally, it is not consistent with national policy. Measures for environmental protection proposed do not address the scale of the problem.
The Response Form asks whether there alternative or additional modifications which you can suggest that would make the BLPSV-PC legally compliant or sound?
- the simple answer is No. Given the surplus of >2000 dwellings (as above) AL21 and 22 should be removed from the Plan.
How do I submit my comments?
Write to the Council setting out your views, and wherever possible, give local examples of how issues affect you and your family. DEADLINE IS MIDNIGHT SUNDAY 15 DECEMBER 2019. You can submit your comments in different ways depending on what is easiest for you:
- Online – using the consultation portal at: http://consult.rbwm.gov.uk/portal or Download – the response form at: http://rbwm.objective.co.uk/file/5513840
- Write – a letter or an email, then scan and email to: firstname.lastname@example.org or Post to: FREEPOST RBWM PLANNING POLICY
What happens next?
There is no precise timetable. RBWM will review representations made on the BLPSV-PC and make such further changes as required to the BLPSV-PC and submit these to the Inspector (expected Spring 2020). Examination could resume with further Hearings from late Spring 2020 onwards. If the Inspector determines that the BLPSV-PC can be made ‘sound’ subject to certain changes a further consultation would then take place on the overall changes to the original Submission Version of the BLP (known as ‘Main Modifications’) which could ultimately lead to formal adoption of the BLP by RBWM.
It is unlikely that the Plan in its current form will be adopted and it is definitely worth continuing to make representations!
8 December 2019
The Windsor Area Development Management Panel that met on Wednesday 4 December voted to refuse the revised application from Bewley Homes Plc and Square Bay (No5) LLP for the erection of 37 dwellings on the Squires site. It was considered that it represented inappropriate development in the Green Belt and that no very special circumstances had been demonstrated to justify development. However if the BLPSV-PC were to be adopted the site would be removed from the Green Belt……
Extract from Housing Site Allocation Proforma
· Approximately 450 residential units
· Strategic public open space
· Formal pitch provision for football and rugby
· Multi-functional community hub
· Educational facilities
· Approximately 39 residential units