BLP-FULL TEXT

Set out below is the full text of the Society’s representations in respect of the Borough
Local Plan Submission Version - incorporating proposed changes (October 2019) :

POUNDFIELD / LOCAL GREEN SPACE
The Society continues to support the designation of Poundfield, Cookham as a
Local Green Space, as set out in Policy IF3. 1. But please see below:

Representations
Para. 14.8.1 The NPPF 2012 has been superseded by the 2019 version. This para. should
be revised accordingly.

Policy IF3; 2.a The Society objects to this element of the policy and wishes to see it
removed. In effect, it imports elements of national policy on Green
Belts, but actually it derogates from the purpose of designating the
land as an LGS for the benefit of the local community. Para. 101 of
the NPPF is clear about how development in an LGS should be
managed and there is therefore no need for sub-paras 2a, 2b or 2c.

Policies Map 1 The annotation of the boundaries of the LGS is insufficiently clear on
the map. This needs to be improved to avoid future argument. (See
email of 27th Nov from Matthew Smith)

NOTE: Part of this land (Ref. 0320) has been wrongly classified as Potentially Deliverable
in the HELAA 2019, when it would clearly not be deliverable within the next 15 years.

HOUSING DEVELOPMENT IN COOKHAM DEAN, ETC (Policy QP5:3)
The Borough’s policy relating to residential development in villages washed-over by
the Green Belt is confused and a basis for uncertainty. The removal of the last sentence in
former BLPSV paragraph 6.8.8 (now 6.16.8) and the reference to the “forthcoming Green
Belt SPD...” indicates that the Borough has abandoned the possibility of creating a regime
which might have defined those instances where limited infilling might be permitted.

Instead, Policy QP5:3 now introduces the need for applicants to define village
envelopes and will delegate to planning officers decisions about settlement boundaries and
“...the concentration, scale, massing, extent and density of built form...” on a case-by-case
basis. Para. 6.16.14 will be a recipe for arbitrary decision making, which is likely to result
in significant, ill-planned development in our rural settlements.

Suggested alternative for Policy QP5:3:
“Limited infilling
The Royal Borough will set out in a Supplementary Planning Document the village envelopes
for those settlements washed over by the Green Belt where it is considered limited infilling
may be permissible. In assessing a village envelope consideration will be given to the gaps
between buildings, concentration, scale, massing, extent and density of built form of the
settlement concerned”.

HOUSING LAND REQUIREMENTS AND PROPOSED HOUSING SITES IN
COOKHAM (Policy HO1)

The Cookham Society objects to para. 7.2.10, Table 7.1 and Policy No. HO1 on the
grounds that, as intended to be revised, in these proposed changes (October 2019) they
would make the BLP unsound.

Table 7.1 indicates that the Borough will now exceed its housing supply target by
2,195 dwellings; i.e 15.4%, a more than adequate buffer given that completions and
commitments are already ahead of forecast. Accordingly, Sites AL37 and AL38 should be
deleted from Policy HO1 since their inclusion can no longer be “fully evidenced and
justified”, as required by para. 136 of the NPPF. The total in Table 7.2.10 should be
adjusted accordingly and the relevant Site Allocation Pro-formas in Appendix C removed.

Site AL37: Land north of Lower Mount Farm

The development of this land would expand the number of dwellings in Cookham by
approximately 10%. The site is not well-served by public transport, as required by para. 138
of the NPPF. Cookham railway station is some distance away, with poor pedestrian access
from this direction, and rail services are only hourly; the bus service is also only hourly, for
part of the day, and there is no evening service.

The Transport Assessment carried out by WSP (dated October 2019) is wholly
inadequate as far as this site is concerned in that it fails to take any account of the
configuration of The Pound and its related road safety issues or Cookham bridge. The
TRICS database, which understates car ownership in this area, suggests an additional 82
cars and light vehicles would leave this site during the a.m. peak hour. Applying an
assignment of 50% of vehicles each north and southbound would suggest an additional one
way load of about 40 vehicles on The Pound during this period. In view of the geometry of
the road: the restricted width of the carriageway and the narrowness of the footway, which is
mostly well below 0.8 metre in width down to as little as 600mm, the potential for serious
accidents between vehicles and pedestrians, especially children going to school, will be
increased significantly.

The one-way signalised operation of Cookham bridge results in long traffic queues
during peak hours. These can extend as far back as the western end of Cookham High Street,
over 200 metres from the bridge. Noxious pollution from standing traffic affects local
residents, especially adjacent to the bridge abutment. Additional traffic will exacerbate
queueing. None of this takes account of any additional loading which would result from the
development of Site AL25: Spencers Farm, which on a 25% northbound assignment would
add a further 34 vehicles through The Pound and northbound over the bridge during the a.m.
peak.

Aside from traffic considerations a public meeting held on 25th November 2019
expressed wide concern about the capacity of the village’s medical centre and the local
schools.

Overall, this site does not meet the criteria for removing land from the Green Belt.
The Borough can no longer claim there are exceptional circumstances justifying its
allocation in order to meet a shortfall in its housing land supply. There are serious and
justifiable concerns about its development impact upon local infrastructure and sustainability
and it should be removed from the list of proposed allocations.

Site AL38: Land east of Strande Park, Cookham

It seems that the Borough has disregarded the Sequential and Exception Test carried
out by WSP (October 2019), which indicates that parts of this site are situated in Flood Zones
1, 2 and 3. It is obviously in a vulnerable location. Indeed, Bullet Point 5 on page 353 of
the BLPSV-PC supports this.

It appears this land may not actually be available for development since at least part
of it is parking and recreation area, which are dedicated to the adjacent Strande Park
residents.

Para. 137 of the NPPF stipulates that “Before concluding that exceptional
circumstances exist to justify changes to Green Belt boundaries, the strategic policy-making
authority should be able to demonstrate that it has examined fully all other reasonable
options for meeting its identified need for development”. There is no evidence that the
Borough has done so. Given the fact that the Borough is now claiming it has an adequate
supply of housing land, to which this site would make only a marginal contribution, there is
no justification for allocating land which may be susceptible to flooding for development.
Consequently, this site should be withdrawn from this list of proposed allocations.

APPENDIX C: Allocation Pro-formas

Without prejudice to the preceding observations, if it is felt necessary to allocate
either of these sites, we would make the following additional comments:

Site AL37: Land at Lower Mount Farm

1. We should like to see a development brief and master plan prepared for the site and
put out to public consultation.
2. Bullet 1: “Provide...housing” should be amended to “Provide a range of housing in
order to create a balanced community, including family housing with gardens, starter
homes, a cluster of self-build plots and 40% affordable housing across all types”.
3. It is not clear to us what the Borough means in Bullet 2 about ‘...green
infrastructure...supporting...food production’. Does this mean allotments?
4. We consider a site of this size should have an element of public open space, including
a Locally Equipped Area for Play.
5. We should like to see a clearer statement about connectivity to and improvement of
off-site pedestrian access to Station Hill.
6. We should like to see measures requiring the developers to secure improvements to
local roads to offset the traffic generated by the development.

Site AL38: Land east of Strande Park.

A. A requirement for self-build clusters (sic) on a site as small as this seems unsuitable.
B. Public open space on a site as small as this appears inappropriate, but provision
should be made for the replacement of any area of open space currently enjoyed by
the residents of Strande Park.
C. Bullet point 5 on page 353 underscores the point we have made earlier: if the land is
likely to flood, it should not be built upon and, given the Borough’s current surplus of
housing land, it should be withdrawn. Developing it would remove land from the
attenuation capacity of the flood plain and would not be sustainable.

TALL BUILDINGS IN COOKHAM AND MAIDENHEAD (Policy QP3a)

The Cookham Society objects to Policy QP3a, (i) in relation to Cookham and (ii) in relation
to Maidenhead Town Centre.

(i) Cookham

The Windsor and Maidenhead Tall Buildings Strategy Final Report (October 2019)
proposes the ‘Cookham Station Node’ as a suitable location for a 4-storey building. This is
suggested as a “Mixed use building to provide active ground floors and street animation,
support regeneration and intensification of activities at [this] local centre, subject to...’
(Page 51 and Table 8.1). Thus is not justified by the evidence.

The area round Cookham station already has variety and vitality and, while the
architecture of some of the modern buildings is mundane and dated, there is no local
suggestion the area requires regeneration. Virtually none of the existing buildings is more
than 2-storeys in height. A 4-storey building here be over-bearing and would have no
relationship with its neighbours. It would introduce a discordant element into an area where
the existing buildings are generally low-key and fit with the grain of their surroundings.

(ii) Maidenhead Town Centre

The Borough’s approach to tall buildings in the centre of Maidenhead has two fatal
flaws:
1) it appears to believe that height is a benefit on its own account: and
2) no distinction is made between residential and commercial buildings.

The BLP appears to take the view that tall buildings are desirable on their own
account. However, over the years Maidonians consistently expressed their dislike of
Berkshire House, which is by no means as tall as those being constructed at the Landing site.
Perhaps the Borough expects a policy of encouraging tall buildings will achieve higher
densities but, as Urban Initiatives Studio Ltd. themselves say in para. 3.9.3 of the Tall
Buildings Technical and Baseline Study (October 2019) (TBTBS): “Tall buildings are not the
only way of achieving higher densities”. Indeed, they quote studies which suggest net
densities of 80-150 units per hectare can be delivered from 3-4 storey buildings. It is not
obvious that the Borough has made any effort to see whether its objectives might be achieved
in an alternative manner. Moreover, paragraph 3.1.3 of TBTBS lists 8 potential adverse
impacts of tall developments. These appear to have been disregarded.

The lack of distinction between residential and office space in such buildings is a
cause for concern. There is a considerable body of evidence which suggests that high-rise
housing is particularly unsuitable for certain households; e.g. the elderly and parents with
small children. If Maidenhead’s town centre requires a pattern of regeneration
incorporating substantially increased housing, the aim should be to create a balanced
community as far as possible. Development should reflect communities rather than vice
versa. A policy for high-rise development will not be successful if operated in isolation from
what happens at ground level.

The success of the policy will rely to a large extent on the quality of the buildings
concerned, but who is to be the judge?

The current proposed Policy QP3a takes a largely mechanistic and ‘one size fits all’
approach to tall buildings. As such it fails to pass the test of sustainability and, therefore,
soundness. So far as Cookham is concerned, we consider the issue of building height should
be left to the proposed neighbourhood plan and Policy QP3a should be amended to ensure
the village is excluded. Since Maidenhead is our nearest commercial centre south of the
river, we are concerned to ensure that its regeneration results in improvement. It is not
apparent to us that Policy QP3a will secure this in a sustainable manner

No comments:

Post a comment

Note: only a member of this blog may post a comment.