SADPD Proposal – the case against Bracknell Forest Council plans

Posted by on Mar 16, 2012 in Binfield, Bracknell | 0 comments

Response by the Northern Arc Action Group
to Bracknell Forest Council’s Draft Submission Site Allocations Development Plan Document

Response Summary

The Northern Arc Action Group is a campaign group formed by local residents in direct response to widespread concerns in the community about the impact of Bracknell Forest Council’s housing development plans on Binfield and Warfield in the northern area of the borough. Founded in 2010 during the Council’s first consultation, there are currently 1,188 members on its facebook site.

The Northern Arc Action Group considers that the SADPD draft submission document is not founded on a credible evidence base, is not legally compliant and is unsound as set out in this document.

Despite its claims, the SADPD fails to follow both national and local policies in the emerging National Planning Policy Framework and its own approved Core Strategy, and is therefore not legally compliant. SAPDP policies SA5, SA6 and  SA7 conflict with Core Strategies CS1, CS2, CS3, CS4, CS5, CS6, CS7, CS8, CS9 and CS15.

Full details are given later in this response document.

Furthermore, Policy SA7 (Blue Mountain Golf Course) is contrary to legally binding agreements signed by the Council and the land owner who is also the proposer of the development.

The plans to locate a secondary school and a football stadium at Blue Mountain are neither justified nor sustainable in this location, and they have not been adequately considered against alternatives. Local residents have not been given the opportunity at any stage of a consultation on any other options for these two particular proposals.

Like many aspects of the SADPD, they are being imposed by the Council without taking the views of the community into account and against the strong objections of more than 2,500 residents. The views of the community have been ignored throughout the whole process, with three consultations proving to be merely a worthless gesture, not engagement in “meaningful” two-way dialogue as indicated by the guidance of the Draft NPPF.  We have been consulted and then ignored – with no significant changes being made to the Council’s “Preferred Option” as a result of the highly expensive consultation exercise.

There are grave concerns over the shortlisting process which reduced the original eight broad area sites proposed to the current four contained as urban extensions in Policies SA4, SA5, SA6 and SA7. All information, discussion and voting on the sites was restricted to the eight-member Executive (three of whom represent wards in Sandhurst where the only site proposed was dropped). At no stage was the full Council of 42 members allowed a free and democratic vote on the choice of sites.

At the Council meeting on 30 November 2011, they were simply asked to adopt the Draft SADPD for submission to the Secretary of State – and a whipped vote was applied by the ruling Conservative party to ensure that the document was approved.

We contend that adopting the SADPD in such a fashion was a breach of the Council’s own Code of Conduct, which therefore renders the Draft SADPD not legally compliant.

Wokingham Borough and Windsor & Maidenhead Councils confirm that they have had no cross-border consultation approaches from Bracknell Forest Council, as required under the Localism Act and the Draft NPPF. Wokingham BC is objecting to the proposals for sites adjoining their boundary.

The scale and location of the three major developments proposed would cause irreversible damage to the traditional village character of Binfield, which has already taken its share of new housing in recent years.

Blue Mountain and Amen Corner North and South are identified in the Council’s own Core Strategy, adopted only four years ago, as Gaps to prevent the coalescence of settlements (Bracknell with Binfield, and Binfield/Bracknell Forest with Wokingham, respectively), and to be protected from development which would lead to the merging of settlements. If the proposals are allowed in their present form, they would result in one continuous settlement, merging Bracknell with Wokingham and losing Binfield’s identity as a separate village. The token minimum amount of green space allocated in the SADPD is insufficient to prevent this happening.

The Council has failed to explore adequately the alternative of converting or redeveloping as affordable housing some of the more suitable 1.5 million sq ft of empty office buildings on brownfield sites in and around Bracknell town centre, its top priority and most sustainable location for housing development, according to the Core Strategy.

Another major green area of the northern arc is to be lost through Policy SA9 (Warfield) which has already been adopted as a major growth location for up to 2,200 homes. Detailed planning discussions with developers are causing great anxiety and anger among residents in that area, and safeguards should be required in the detailed plans to ensure that Cabbage Hill is free from all development in order to protect its wildlife and the open vista which are important to the quality of life for residents; and to protect the village identity of old Warfield from being lost through coalescence with the new development.

 

In the report on the Examination into the Core Strategy DPD in 2007, the Inspector noted:

“Whilst the detailed layout of CS5 (Warfield) will be developed through an AAP (Area Action Plan), the Council will seek to secure the majority of Cabbage Hill as publicly accessible open space.”

 Of particular concern to the NAAG is the fact that the Council has based the development of the whole north Bracknell expansion area on the delivery of a secondary school at Blue Mountain, which has legal constraints on it. Local residents are prepared to fight through the courts against any variation of Section 52 and lease agreements on Blue Mountain, which could threaten the deliverability of the only new secondary school site considered by the Council. It has steadfastly refused to consider alternative options, although this is the least sustainable option, representing the greatest distance for the maximum number of pupils to travel.

In summary, the key issues of our case are:

  • Dependence on the availability of Blue Mountain Golf Course for development is unsound due to legal constraints
  • Locating a secondary school for the whole north Bracknell expansion area at Blue Mountain is unsustainable and may be undeliverable
  • There are major conflicts with the Council’s adopted Core Strategy
  • The proposals fail to meet many of the objectives of the emerging National Planning Policy Framework
  • Bracknell Council’s 10,780 Housing Demand Forecast for the period 2006-2026 is overstated and not founded on a credible evidence base
  • The consultation carried out by Bracknell Forest Council is flawed
  • There was inadequate assessment of alternatives when choosing the “preferred” broad areas
  • The Infrastructure Delivery Plan (SAL 34) which supports the Draft SADPD is unsound
  • Provision for healthcare needs in the SADP is unsound

The above assertions are each covered in more detail, together with supporting evidence, within the body of this document.

We would like to make it clear that the Northern Arc Action Group is not against new housing being built, nor does it contend that north Bracknell is the wrong location for some new development. But residents are very concerned about the cumulative impact of Bracknell Forest’s housing development plans when considered alongside those of neighbouring Wokingham Borough Council.