This submission is made by the Oakley Green & Fifield Residents Association (“OGFRA”). It follows previous submissions at all stages of the Borough Local Plan Consultations and participation in the Examination. OGFRA is also one of the 12 organisations (previously 13 organisations before SportsAble had to close) who have combined to provide substantial evidence throughout the Borough Local Plan Consultations and Examination and thissubmission should be read as complementary to the evidence submitted on behalf of the 12 Organisations. It isintended to focus on issues directly affecting the Oakley Green and Fifield area.
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 developmentof 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.Whilst a number of positive changes have been made in the Main Modifications the AL21 and AL22 site allocations remain with only minor changes and the issue of A308 capacity is not addressed.
We have previously set out our objections to site allocations AL21 and AL22 in detail, and do not intend to repeatthese here. However we set out below comments in relation to five issues that we consider need to be addressed inrelation to the Main Modifications Consultation:
- A308 capacity
Of fundamental importance to site allocations AL21 and AL22 and wider issues relating to congestion, noise and air pollution throughout the Borough is the ability of the A308 to cope with increased traffic flows. We have two areas of concern – the failure to progress the A308 corridor study and further developments planned along the A308 whichhave emerged during the Borough Local Plan process which will exacerbate capacity issues:
- A308 corridor study. We understand that very little progress has been made with the crucial A308 study, partfunded by central government way back in In responding to the various BLP consultations OGFRA has consistently argued that no further development along the A308 (including the allocated sites) should beallowed 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 study has not been given thepriority it deserves and consider that Main Modifications are required to address A308 capacity issues and that any planned development of allocated sites along the A308 should be paused until the A308 study hasbeen completed and its recommendations (and associated funding requirements) have beenimplemented/identified.
We acknowledge the positive changes to Policy IF1 in Section 14.3 (MM45) on Infrastructure andDeveloper Contributions, namely in “Development proposals must, where appropriate, deliver infrastructure to support the overall spatial strategy of the Borough, including making contributions to the delivery of all relevant infrastructure projects included in the IDP in the form of financial contributions or on site provision.” However the failure to progress the A308 study means that the IDP does not identify necessary infrastructure projects required to address the ‘overload’ on the A308 and its feeder roads.
We also note in Policy EP2 (Air Pollution) the new para 13.4.3 (MM41) “It will be important to ensure that new development is carefully phased so that it does delay compliance with air quality standards in zones which are currently out of compliance, or cause non-compliance to occur during the period leading up to 2032.” Whilst this modification is not subject to re-consultation we would simply observe that the failure to progress the A308 study means that the greater threat to air quality has not been properly considered and site selection therefore compromised.
It seems that the Borough’s approach to the serious issues on the A308 is to deal with them on a piecemeal basis with developers. Site Proformas providing for measures such as Travel Plans, appropriate publictransport, car sharing etc. However such site specific measures cannot possibly address the wider issues on the A308 and we consider that the BLP cannot be viewed as sound in such circumstances.
- Further developments. Recent developments that will further increase pressure on the A308 include:
- approval of the Aldi discount store on Green Belt land on Dedworth Road in October 2020 (application 20/01145). The Aldi site is (and remains) part of the AL21 allocation and at no stage was any suchretail development contemplated under the BLP
- plans for the ‘permanent’ redevelopment of Bray Studios to create new film and TV studios (application no. 21/02245 submitted July 2021)
- approval in July 2020 (application 18/03167) for 10 years of sand and gravel extraction/infil on landopposite Bray Studios with all materials to be processed off-site at the nearby processing plant onMonkey Island Lane (with all movements in/out by lorry).
- the Borough remains committed to development of the Maidenhead Golf Club (MGC) site and hasrecently submitted a revised offer to The outcome is unclear at this time, but if this proceeds MGC has examined development of a new golf course at Fifield adjacent to the A308
- Bracknell Forest pushing ahead with plans for 2,000 new dwellings at Jealotts Hill which willundoubtedly impact local
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) and emphasises the importance of the A308 study to examine the totality of all planned/potential development.
- Climate change/flooding
There is increasing global concern with climate change causing more extreme weather and an increased risk of flooding – and both sites AL21 and AL22 suffer from surface water flooding. We note that in the new Policy SP2 in Section 5.5 para 2 (MM6) that “ Adaptation measures need to be built into all new developments to ensure thesustainable developmentof housing, businesses and the economy of the Royal Borough.” However this policy needs to be far more prescriptive on what constitutes ‘adaptation’ measures for it to be effective, and we consider that the extent ofdevelopment permitted on such sites should be reconsidered in light of the increased flooding risk.
- Heritage assets
We welcome the positive changes in MM34 to (a) para 11.1.3 which includes “The preparation of a local list that details local heritage assets will be one of the outcomes related to the Heritage Strategy and this local list will beupdated via the Annual Monitoring Report. However, non-designated heritage assets may also be discovered througha number of different processes, including the making of neighbourhood plans, Conservation Area appraisals orthrough the consideration of planning applications.” and (b) policy HE1 Historic Environment para 1 which includes “Development proposals would be required to demonstrate how they preserve or enhance the character, appearance and function of heritage assets (whether designated or non-designated) and their settings, and respectthe significance of the historic environment.” We have two observations:
- the existing policy (or its interpretation by the Borough Conservation Officer and Planning Panel) failed to give appropriate protection to the Grade II* Old Farmhouse adjacent to AL21 which has suffered damage and disturbance during construction of the Aldi discount store (and will be impacted by the proximity of the store and delivery ramps post construction). The revised Site Allocation Proforma states “conserve, orpreferably enhance, the Grade II* listed The Old Farmhouse and its setting” and the developer of AL21 needs to very clearly demonstrate this.
- an area adjacent to AL21 and AL22 has recently been recognised by both The Windsor & Eton Society and the Borough’s Principal Conservation Officer as a non-designated heritage asset and should benefit from thisenhanced The area in question is the ‘Willows Estate’, north of the A308, and extending along both sides of the ‘Old Maidenhead Road’. The area is enclosed by a distinctive low wall (1.5 metres high inplaces) and any development proposals for AL21 and AL22 should be “required to demonstrate how theypreserve or enhance the character, appearance and function of these non-designated heritage assets”. Based on the current Stakeholder Masterplan process being conducted by the prospective developer of AL21 (Wates) and the Borough it is not clear that they intend to give this the priority required by the revised policy wording, and we would ask that the Site Allocation Proformas make specific reference to the Willows Estateand provisions of HE1.
- Site Allocation Proformas
We are concerned by the new language in Policy HO1 in Section 74 para 4 (MM16) on housing site proformas – ”In meeting the proforma requirements, flexibility may be applied to allow for material changes in circumstance as a result of the passage of time or to enable alternative solutions that will deliver the same, or preferably, a better planning outcome.” This appears to undermine the Site Proformas and give developers the opportunity to avoid keyrequirements, which we assume is not the intention. Clearly Site Proformas need to recognise ‘external’ changes that occur – as for example the NDHA designation referred to above – but that should be picked up by the planningprocess and we consider that the additional flexibility introduced in para 4 should be deleted.
- Cardinal Clinic
We have consistently stressed the importance of the Cardinal Clinic mental health facility and noted the repeatedfailure of the Borough to recognise this. Finally the revised Site Allocation
Proforma for AL21 now provides “consider and avoid or, where necessary, mitigate potential disturbance impacts on the users of the Cardinal Clinic”. The grounds of the Cardinal Clinic are valued and used by patients and it is important that a suitable ‘buffer’ is set around the perimeter for the benefit of patients (and any occupiers ofadjoining land). The Aldi development has had a detrimental impact on the operation of the Cardinal Clinic and it isimportant that these mistakes are not repeated. We would ask that reference to a suitable ‘buffer’ is included in the Site Proforma.
IN SUMMARY we consider that the principal matters raised in issues 1, 2 and 4 above need to be addressed for the revised Borough Local Plan Submission Version Main Modifications to be considered sound and would also ask thatthe additions to the Site Proformas in relation to the WiIlows Estate and Cardinal Clinic set out in issues 3 and 5 are also made.
5 September 2021
This Submission is made on behalf of the Oakley Green & Fifield Residents Association. Contact by email at firstname.lastname@example.org or by post to Martin Hall, Chairman, Oakley Green & Fifield Residents Association, No Oaks,Oakley Green Road, Oakley Green SL4 4PZ