THE COOKHAM SOCIETY
LOCAL
PLAN PREFERRED OPTIONS CONSULTATION 2014
CONSOLIDATED
REPRESENTATIONS
Local
Plan
section
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Local
Plan question no.
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Society’s
reference
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Cookham
Society’s representations
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2: Spatial portrait
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1
2
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Comment:
Section 2.3 does not
recognise the proportion of population which will be of retirement age by the
end of the period (2029)
Comment:
Section 2.4 has nothing to
say about the arrival of Crossrail and its impact.
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3: Vision and objectives
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1
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3
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Comment:
Insufficient attention to
catering for the elderly who may make up to 25% of population by end of
consultation period.
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2
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4
5
6
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Objective 1: no comment.
Objective 2: no comment.
Objective 3: no comment.
Objective 4 is
not being fulfilled because of the loss of more than 26 hectares of
employment land (Comment).
Objective 5: no comment.
Objective 6 – Comment:
There needs to be a ‘Plan B’ for those who cannot stay in their own
homes.
Objective 7: no comment.
Objective 8: no comment.
Objective 9: Comment:
Do not deny the reality of greatly increased car ownership; i.e.
allow for parking for Crossrail.
Objective 10: no
comment.
Objective 11: no
comment.
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4: Strategy
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3-4
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7
8
9
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Comment: The Strategy is deficient because it
provides no correlation between the provision of jobs and the need for
housing. Para. 4.2.3 does not say
what a ‘sustainable balance’ is/should be.
Objection: The Strategy is deficient because it
provides no correlation between the provision of jobs and the need for
housing. Para. 4.2.3 does not say
what a ‘sustainable balance’ is/should be.
The methodology used to evaluate the Green Belt in the Green Belt
Purpose Analysis document is flawed in that it fails to recognise the reality
of settlements washed over by the Green Belt and thus fails properly to
address the purposes of the Green Belt in the NPPF.
Comment: Para. 4.2.7 would be improved by the
addition of: “.…recognising that preservation of the environment
in some areas addresses an important social need – that of leisure and access
to areas of environmental attractiveness".
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5
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No comment
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Community-led development
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6
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10
11
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Comment on section 4.5.3: In this area any
community led development would be unlikely to meet the requirement that it
should not significantly increase the sales land value.
Objection to Preferred Policy Option (PPO)
BLP2: The criteria set out in PPO BLP2 are far too loose and need to be
tightened up in order to protect interests of acknowledged importance.
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5: Quality of place
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Design
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7
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12
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Support, subject to suggested
amendments, as follows: (1) Insert in PPO PLA1 - proposed partnerships: new
point 3: Qualified architects to ensure consistency of design where
appropriate.
and (2) add: Local communities will
be encouraged to produce Village Design Statements to help achieve the aims
of this PPO.
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Maidenhead
Town Centre
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8
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13
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Objection to
para. 5.1.6, PPO PLA1 and Question 8: The appropriate place for considering
increased heights of buildings in Maidenhead Town Centre is through a review
of the Area Action Plan.
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Townscape and landscape
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9
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14
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Objection to para. 3 of PPO PLA2: The Landscape Character Assessment
was too broad brush to provide a meaningful assessment of development
proposals. This paragraph can be
removed and the issue dealt with under PPO GBC 2.
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Thames riverside corridor
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10
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15
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Support Question 10, subject to addition of the following at
the end of closing para. to PPO PLA3: “… and where they will not have an impact on
the openness of the Green Belt”.
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6: Green Belt and countryside character
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11
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16
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Support para. 6.1.1, subject to
the following modification: Add at end of point 4: “…provided that it is demonstrated that
they are no longer required for agricultural purposes”.
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Green Belt
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17
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Objection to
PPO GBC1: Policy requires amendment in para 2
by addition of: “Where it is determined to the Council’s
satisfaction that the need exists for Rural Exceptions Housing, the Council
will give favourable consideration to the adjustment of Recognised Settlement
boundaries to enable that need to be met”.
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Minor adjust-ments to the
Green Belt
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12
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18
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Comment:
Site ref. WMCO0012 in Rejected
Sites - Housing Site Assessments: Land adjoining Lee Cottage, School Lane,
Cookham does not serve any of the purposes of the Green Belt defined in the
NPPF and does not reflect the boundary of the built-up area. Recommend taking out of Green Belt and
inclusion in settlement of Cookham.
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19
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Comment:
The Holy Trinity Church Paddock (Map1: Cookham) does not serve any
of the purposes of the Green Belt defined in the NPPF and this site should be promoted as a Community Asset or Local Green Space and not
included in the Green Belt.
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Countryside character
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13
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20
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Comment:
PPO GBC2: Suggested replacement of 4th bullet point relating
to supported types of development: “limited
infilling in villages, and limited affordable housing for local community
needs in Recognised Settlements (refer to…”.
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21
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Objection to
PPO GBC2. There is no mention
of the previous policy concerning the Area of High Landscape Importance in
the north of the Borough and this needs to be reinstated.
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New residential
development in the Green Belt
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14
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22
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Objection to PPO GBC3 and Question 14.
(1) Suggested addition to Bullet Point 3: “…which is contiguous to the main
dwelling and does not exceed ?% of the main dwelling”;
(2) Suggested addition to
Bullet Point 4: “…provided that the
ground floor area of the replacement dwelling exceeds the original by no more
than ?%”;
(3) Suggested addition to
bullet point 5: "..which should be
contiguous to the Recognised Settlement boundary".
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Re-use and replacement of
non-residential
buildings in the Green
Belt
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15
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23
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Comment: Note: para. 6.4.3. The
permission only partly expires in 2016
AMEND
PPO GBC4 In heading and first sentence take out
"replacement". Insert in
first line after “..replacement of buildings” “for business or industrial use…”.
Reason: Otherwise it does not appear to prevent the replacement of
agricultural buildings with houses. First bullet point should be longer than
4years. There should be a strict test for redundancy before change of use is
allowed together with a withdrawal of permitted development rights for new
agricultural buildings on the entire holding.
OBJECT to PPO GBC4 for
reasons set out above.
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Major developed sites in
the Green Belt
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17
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24
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Agreed
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7. Housing
Amount and distribution
of housing
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18
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25
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Object to
PPO HOU1, supporting paras and Question 18
1.
The sum of the figures in Table 3 does not match the total in Table 2.
2.
The number of dwellings specified for Cookham in Table 3 is
unachievable.
3.
The Borough’s estimated supply from windfall (1,778) is not likely to
be achieved
4.
There is no consideration of whether phasing is desirable.
A more robust assessment of supply is required.
The Borough should have considered a more strategic approach to
meeting housing need; e.g. the identification of a new ‘township’, before
adopting the current approach of chipping away at the Green Belt.
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Allocated housing
development sites/sites in the Green Belt
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19/20
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26
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Object to
Table
6 and Question 20.
Area west of Whyteladyes
Lane, Cookham.
(a) The methodology used
In Green Belt Purposes Analysis document is flawed in that it fails to give
weight to nearby settlements which are ‘washed-over’ by the Green Belt.
(b) Development here would
reduce the separation between Cookham Rise and Cookham Dean, and has been
recently rejected on appeal (see appeal ref: APP/T0355/A/13/2206932)
(c) Thames Water has noted
that further development cannot be sustained without upgrading the
sewers. This is unlikely to occur for
many years because of the scale of upgrade required.
(d) The site is crossed by
2 major gas mains, which would be expensive to relocate.
(e) There is a Source
Protection Zone in the locality which needs to be protected.
(f)
There would be no obvious benefit to the local community for
development here.
Area around Spencer’s
Farm, Maidenhead
(a) Development of this
site would represent an unacceptable incursion into the Green Belt within the
narrow gap between Maidenhead and Cookham.
To provide a proper access to this development would be very difficult. Because of the proximity of the railway,
it is very difficult to access the site from the west and no obvious
alternative access points can be provided either without major road
construction in a south-easterly direction or through the Aldebury Road estate,
whose road layout has not been designed for 500 extra dwellings and would
result in an unacceptable loss of amenity for exiting residents. 2 accesses would be required. Proper servicing of this land would
require the construction of a new road between Cookham Road and Sheephouse
Road. Recent aerial photography
suggests the extent of future flooding is likely to be greater than
previously predicted (see attached photograph looking north from Lutmans Lane).
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Meeting a range of
housing needs
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22
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27
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Object to PPO HOU3 and Question
22. We support the principle of meeting a
range of housing needs, but we strongly object to the final para. of PPO HOU3
and paras. 7.3.6 to 7.3.8. It appears
to us from the briefing held in Cookham on 11th February that the Borough
does not distinguish between Residential Care and Nursing Homes. It is accepted that it is desirable, as
far as possible, that the elderly should be able to be cared for in their own
homes; however, this is not suitable for all. It has to be accepted that an
ageing population will increase the need both for care homes and for nursing
care and the local plan should allow for these types of provision so that the
elderly can be looked after close to friends and family and not forced to go
outside the Borough.
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Affordable housing
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23
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28,29,30
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Object to para 7.4.5. The para.
should be re-written to make clear (a) it is referring to Rural Exceptions
Sites, and (b) RE sites will only be permitted in Recognised
Settlements. Otherwise there could be
sporadic ‘RE’ housing anywhere in the Green Belt.
Object to PPO HOU4. We have no problem in principle about the
reduction in affordable housing thresholds.
However, the Borough has not demonstrated what effect this reduction
will have on windfall sites, which we believe will result in a reduction of
about 35% in windfall housing. The thresholds should be regarded as the
maximum requirement allowing for a degree of flexibility in application.
Object to PPO HOU5. Suggest inclusion of an additional bullet point: “h.
New Rural Exceptions Housing will only be acceptable within Recognised
Settlements”.
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Affordable Housing –
shared equity
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24
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31
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Object to Question 24. This question implies that the Borough will seek to prefer
Shared Equity or Shared Ownership over affordable rented housing. However, a large proportion of those in
need of affordable housing are unable to afford these two types of tenure.
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Affordable Housing –
Rural Exception sites
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25
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32
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Object to
Question 25 (for reasons set out above).
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Protection of residential
land and the housing stock
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27
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33
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Support
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Housing layout and design
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28
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34
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Object to PPO HOU8. A further
bullet point should be added: “In residential estates dwellings should be laid
out in such a way as to ensure surveillance and assist in crime reduction”.
Support Question 28, subject to the amendment
proposed above.
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Housing density
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29
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35
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Support PPO HOU9 and
Question 29, subject to the
following
amendment - Insert at end: “…provided
that all parking
needs should be met on site”..
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Conversion of dwellings
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30
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36
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Support.
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Development involving
residential gardens
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31
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37
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Support
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Extensions and
outbuildings within a residential curtilage
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32
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38
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Object to Bullet Point G of PPO HOU12. A
proviso should be added to
prevent outbuildings in
advance of front building
lines.
Support
Question 32, subject to the insertion of the proviso above.
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Residential amenity
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33
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39
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Object to Bullet Point G. Remove “unacceptable”. Nuisance, pollution and contamination are by definition
unacceptable.
Support Question 33, subject to the correction
above.
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8. Economy
Economic development
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34
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40
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Comment on paras. 8.0.3 to 8.0.5. More than 26 ha. will be lost to
employment uses in this plan, much of which is currently in use by Small and
Medium-sized Enterprises, which are important for their function in servicing
the local economy. We do not consider
the Council is best placed to be the judge of whether one type of employment
activity is better than another. The
needs of the whole spectrum need to be addressed.
Object to PPO EC1. This aspiration is undermined by other policies in the
plan. See above.
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Defined employment sites
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35
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41
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Object to the inclusion of Lower Mount Farm in
Table 8. This site only has the
benefit of a temporary planning permission.
It is a non-conforming use within the Green Belt and permanent
planning permission should not be granted.
Object to Question 35, consequential on comments
above.
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Other sites and loss of
employment uses
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36
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42
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Object to PPO EC3. This PPO is inconsistent with the removal of 26 ha. from
employment uses to residential.
Object to Question 36, consequential on comments
above.
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9. Town Centres and
Retail
Maidenhead and Windsor
Town Centres
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38
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43
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Object to PPO RET2: What does the Borough mean by
‘a high proportion’? A lack of
definition is unhelpful.
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10. Tourism
Tourism development
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42
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44
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Support PPO TM1, subject to
the following comment: Much of the
Thames lies within the Green Belt/countryside. Any tourist-related development should be subject to the strict
controls on development for these areas promoted in other parts of the plan.
Support Question 42, subject to PPO TM1 being
improved to acknowledge the concerns expressed above.
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Visitor accommodation
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43
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45
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Object to PPO TM2. Paragraph 2 of the PPO needs to be modified to ensure the
siting of campsites and holiday parks is not detrimental to the countryside.
Object to Question 43. The PPO does not allow for the protection of the countryside.
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11. Historic environment
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44
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46
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Object to PPO HE1. The policy proposes the continuation of the present reactive
approach. A proper Local Heritage
Asset Register should be commissioned.
Object to Question 44 consequential on above.
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Archaeology
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47
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47
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Object to PPO HE4. The policy proposes the continuation of
the present re-active approach. A
proper Local Heritage Asset Register should be commissioned
Object to Question 47 consequential on above.
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12. Natural resources
Preferred areas for new
waste facilities
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55
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48
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Object to PPO NR5. Hindhay Quarry should be removed from the list of sites where
further development will be supported, since it is too close to existing
residential properties.
Object to Question 55 consequential on above.
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Renewable energy
generation
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59
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49
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Object to PPO NR9 and Question 59.
As written the PPO would give a blank cheque to any such development
in the open countryside without any reference to the scale of develop-ment. The bullet points in the PPO need to be
beefed up significantly if this policy is to be made acceptable.
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Managing flood risk and
waterways
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60
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50
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Support PPO NR10, subject to a
requirement that any new development should be subject to an obligation to maintain any
watercourse on or adjoining the site.
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13.
Environmental protection
Air pollution
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62
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51
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Object to PPO EP2 and Question 62. The PPO is far too permissive. Since the
PPO refers to AQMAs, no proposals should be supported which increase air
pollution.
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Artificial light
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63
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52
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Support PPO EP3 and Question 63.
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Contaminated land and/or
water
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65
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53
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Comment: This PPO (EP5) would imply that the
proposed residential site west of Whyteladyes Lane, Cookham, which would be
likely to affect an SPZ, should be deleted
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14. Natural environment
Open spaces
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69
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54
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Comment: It is not possible to provide any
meaningful input since the supporting material is not complete. But open
spaces are important and the development of criteria for assessment (proposed,
but not developed) should be a priority.
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15. Infrastructure
Sustainable transport
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73
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55
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Comment: In the light of (a) the arrival of Crossrail, and (b) the revival of
Maidenhead Town Centre, the Local Plan needs to spell out how access and
parking are going to be provided to cater for these developments. It is not sufficient to leave these
important matters to the Local Transport Plan, which does not cover them
adequately.
OBJECT to Question 73, consequential on the
above.
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Developer contributions
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74
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56
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Support.
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Water supply and sewerage
infrastructure
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76
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57
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Support and comment: Since much of the
existing water and sewerage infrastructure is ageing, we would expect strong
requirements for improved facilities
for new developments.
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