OBSERVATIONS OF TOWN/PARISH COUNCIL

PARISH! APPLICATION NO.

LOCATION AND APPLICANT

PROPOSAL

Firtands Farm Hollybush Lane Burghfield Common Reading Berkshire RG73JN

Outline application for the erection of 129 dwellings with vehicular access on to Hollybush Lane and associated public open space, landscaping and drainage work. Matters to be considered: Access.

14/01730/0UTMAJ HOD Burghfield Common Ltd

Date of despatch by WBC: 15th July 2014

Comments to be returned by 5th August 2014

Burghfield - Adjacent Parish

D NO OBJECTIONS

D SUPPORT OBJECT

REASONS:

All relevant documentation may be viewed on ~ Council's website at the following address' http://plannmg.westberks.gov uk/rpp/index asp?caseref= 14/01730/0UTMAJ

Burghfield Parish Comments to the Outline Planning Request:

Reference: 14/01730/0UTMAJ

Site Address: Firlands Farm Hollybush Lane Burghfield Common Reading Berkshire RG73JN

Summary of the Outline application for the erection of 129 dwellings with vehicular application: access on to Hollybush Lane and associated public open spaces,

landscaping and drainage work. Matters to be considered: Access. Burghfield Parish Council's Objection response:

Burghfield Parish Council Comments;

1. Introduction

[O.BPC] Burghfield Parish Council are not against all development within or adjoining the Parish. Smaller pockets of development that have less immediate impact on the rural character of the Parish and the supporting infrastructure are preferred.

[l.BPC] Burghfield Parish Council does not agree that this development would achieve the above aim, resulting in a detrimental effect to the site and the surrounding area.

[2.BPC] Burghfield Parish Council does not believe the following policies have been met to satisfy the criteria for approval, we therefore object to this application.

2. Achieving Sustainable Developments

[3.BPC] After assessing the proposed development and associated documentation, Burghfield Parish Council's conclusion is that the request for Outline Planning permission does not meet the strategic policies outlined by Central and Local Government. Specifically under the major headings of Economic, Social and Environmental:

From the National Planning Policy Framework, (March 2012) Page 2, Paragraphs 6 to 10

6. The purpose of the planning system is to contribute to the achievement of sustainable development. The policies in paragraphs 18 to 219, taken as a whole, constitute the Government's view o/what sustainable development in England means in practice for the

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planning system.

7. There are three dimensions to sustainable development: economic, social and environmental. These dimensions give rise to the need for the planning system to perform a number ofroles:

¥ an economic role - contributing to building a strong, responsive and competitive economy, by ensuring that sufficient land of the right type is available in the right places and at the right time to supportgrowth and innovation; and by identifying and coordinating development requirements, including the provision of infrastructure;

[4.BPC] The location proposed for this development is outside the current Settlement Boundary, encroaching into woodland and agricultural land. There is an immediate contravention of National policy as this is considered to not be the right place or the right type of land for this style of development, taking land and putting in place unproductive housing.

[5.BPC] From an economic standpoint, this development does not offer a mix of residential and employment units resulting in people having to commute outside the immediate area for work in Reading and London. It would therefore not bring any large economic benefit to the local community, or the wider district. The construction of such a development would require builders from outside the area as preferred to local tradesmen and associated building su ppliers. This would be in contravention of this policy:

¥ a social role - supporting strong, vibrant and healthy communities, by providing the supply of housing required to meet the needs ofpresent and future generations; and by creating a high quality built environment, with accessible local services that reflect the community's needs and support its health, social and cultural well-being; and

[6.BPC] By destroying the natural environment, it neither supports the heath, social or cultural well-being of the community. It brings additional pressure on the already stretched school places.

¥ an environmental role - contributing to protecting and enhancing our natural, built and historic environment; and, as part of this, helping to improve biodiversity, use natural resources prudently, minimise waste and pollution, and mitigate and adapt to climate change including moving to a low carbon economy.

[7.BPC] The proposed development does not contribute to the protection or enhancement of the natural, built or historic environment. It would contribute to the destruction of biodiversity and the loss of visual amenity the community currently enjoys. The additional housing increases the requirement of natural resources in terms of heating (increase of the carbon footprint) and water as well as the waste being generated in all its forms, does not support this policy.

From the National Planning Policy Framework, (March 2012) Page 2, Paragraph 8;

8. These roles should not be undertaken in isolation, because they are mutually dependent.

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Economic growth can secure higher social and environmental standards, and well­ designed buildings and places can improve the lives of people and communities. Therefore, to achieve sustainable development, economic, social and environmental gains should be sought jointly and simultaneously through the planning system. The planning system should play an active role in guiding development to sustainable solutions.

[8.BPC] Following on from Paragraph 7 to Paragraph 8, which clearly states that each subparagraphs of Paragraph 7 should not be taken in isolation, it is clear that this proposal does not fully support each of those roles sufficiently to justify this proposal.

From the National Planning Policy Framework, (March 2012) Page 2, Paragraph 9 & 10;

9. Pursuing sustainable development involves seeking positive improvements in the quality of the built, natural and historic environment, as well as in people's quality of life, including (but not limited to):

¥ making it easier for jobs to be created in cities, towns and villages;

¥ moving from a net loss of bio-diversity to achieving net gains for nature.s

¥ replacing poor design with better design;

¥ improving the conditions in which people live, work, travel and take leisure; and

¥ widening the choice of high quality homes.

10. Plans and decisions need to take local circumstances into account, so they respond to the different opportunities for achieving sustainable development in the differing areas.

[9.BPC] This is also the case for Paragraphs 9 and 10, page 3 of the NPPF.

3. Core planning principles

From the National Planning Policy Framework, (March 2012), Page 5, Paragraph 17;

Core planning principles 17. Within the overarching roles that the planning system ought to play, a set of core land­ use planning principles should underpin both plan-making and decision-taking. These 12 principles are that planning should:

¥ be genuinely plan-led, empowering local people to shape their surroundings, with succinct local and neighbourhood plans setting out a positive vision for the future of the area. Plans should be kept up -to -date, and be based on joint working and co -operation to address larger than local issues. They should provide a practicalframework within which decisions on planning applications can be made with a high degree of predictability and efficiency;

¥ not simply be about scrutiny, but instead be a creative exercise in finding ways to enhance and improve the places in which people live their lives;

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¥ proactively drive and support sustainable economic development to deliver the homes, business and industrial units, infrastructure and thriving local places that the country needs. Every effort should be made objectively to identify and then meet the housing, business and other development needs of an area, and respond positively to wider opportunities for growth. Plans should take account of market signals, such as land prices and housing affordability, and set out a clear strategy for allocating SUfficient land which is suitable for development in their area, taking account of the needs of the residential and business communities;

¥ always seek to secure high quality design and a good standard of amenity for all existing andfuture occupants of land and buildings;

¥ take account of the different roles and character of different areas, promoting the vitality of our main urban areas, protecting the Green Belts around them, recognising the intrinsic character and beauty of the countryside and supporting thriving rural communities within it;

¥ support the transition to a low carbon future in a changing climate, taking full account of flood risk and coastal change, and encourage the reuse of existing resources, including conversion of existing buildings, and encourage the use of renewable resources (for example, by the development of renewable energy);

[10.BPC] The proposed development is based on the West Berkshire Strategic Housing Land Availability Assessment (SHLAA) document, which identified land for POTENTIAL development, not land that is allocated for development. In this case, the developer has been premature in their application as the core principle of the NPPF is for "Plan Lead" development. The current preferred option consultation is currently live where this specific area is not identified as one ofthe "preferred options".

[ll.BPC] Although existing and previous use is not necessarily of the highest environmental quality according to reports compiled by the developers, consideration should still be given to the fact that this is an open green space of undeveloped land. The environment will not be enhanced by this development. Concern is raised regarding no mention of the use of renewable resources, therefore the development cannot claim to be sustainable.

[12.BPC] Social progress would be limited with this development. While the site may be of a poor grade agricultural land type, it is still a natural resource that needs to be used prudently. It is the considered view of Burghfield Parish Council that the proposed development of the land would not enhance the physical environment to the benefit of the community.

[13.BPC] The proposal would substantially increase the physical size of Burghfield Common. Concerns are raised regarding the potential for the social fabric of the local communities being weakened in not just Burghfield Common, but the surrounding areas of Sulhamstead and Ufton Nervet. It therefore does not meet this or other aspects ofthe policy.

[14.BPC] There are no statements within the proposal suggesting how the mitigation of climate change would be achieved. From this limited point, it would consume more

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resources over a long period of time, in terms of water, electricity, oil/gas (heating) and produce waste that needs disposing of presumably straight into landfill. This results in a further contravention of Government policy.

[15.BPC] The proposal does not meet the requirements of the policies in the NPPF, page 9, Paragraph 28 in that that it neither facilitates nor supports those who maintain the country side. It does not promote traditional land based activities that support both leisure and recreational activities.

[16.BPC] The proposal does not address the transport issues specific to a rural area. The proposal expunges the virtue of walking, cycling and Public Transport. No immediate bus route would result in a private car being required by the majority of residents not just within Burghfield Common, but by the greater Kennet Valley area and beyond. As this is the main thrust of the proposal, It is in contravention of the NPPF, (March 2012), Page 9, and Paragraphs 29 through to 41.

[17.BPC] Moving to West Berkshire's Local Plan (the Core Strategy); page 19-20;

Area Delivery Plan Policy 1 Development in West Berkshire will follow the existing settlement pattern and comply with the spatial strategy set out in this document.

Most development will be within or adjacent to the settlements included in the settlement hierarchy set out below, and related to the transport accessibility of the settlements (especially by public transport, cycling and walking) and their level of services. The majority of development will take place on previously developed land.

West Berkshire's main urban areas will be the focus for most development. The most intensively used developments, intensive employment generating uses, such as B1(a) offices, and intensive trip generating uses, such as major mixed use, retail or leisure uses, will be located in those town centre areas where the extent and capacity of supporting infrastructure, services and facilities is the greatest. High densities of development may be appropriate in these locations. Such development will have to be comprehensively planned in order to deliver maximum social, environmental and economic benefits to the wider community.

The scale and density of development will be related to the site's current or proposed accessibility, character and surroundings. Significant intensification of residential, employment generating and other intensive uses will be avoided within areas which lack sufficient supporting infrastructure, facilities or services or where opportunities to access them by public transport, cycling and walking are limited.

District Settlement Hierarchy

Urban Areas Wide range of services and the focus for the majority of development - delivery of

Newbury, Thatcham, Eastern Urban Area (Tilehurst, CalcDt

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approximately 6,900 new homes and Purley on Thames) Rural Service Range of services and reasonable public transport Burghfield Common, Centres provision - opportunities to strengthen role in Hungerford, Lambourn,

meeting requirements of surrounding Mortimer, Pangbourne, Theale communities - delivery of approximately 2,000 new homes

Service Villages More limited range of services and some limited Aldermaston, Bradfield development potential- delivery of Southend, Chieveley, Cold Ash, approximately 1,100 new homes. Compton, Great Shefford,

Hermitage, Kintbury, Woolhampton

Below the settlement hierarchy there are two additional types of area where there will be more limited development, including affordable housing for local needs:

¥ Smaller villages with settlement boundaries - suitable only for limited infill development subject to the character and form of the settlement.

¥ Open countryside - only appropriate limited development in the countryside will be allowed, focused on addressing identified needs and maintaining a strong rural economy.

[18.BPC] Notes in the WBDC Core Strategy Area Delivery Plan Policy 1, state that Burghfield Common is a Rural Service Centre as defined under the District Settlement Hierarchy. It is also noted that under Area Delivery Plan Policy 1, 2nd paragraph, "The majority of development will take place on previously developed land." This proposal is not.

[19.BPC] Paragraph 3 states that the main focus for most development would be in the main urban areas. Under the District Settlement Hierarchy, Burghfield Common is not an urban area, but a Rural Service Centre. The application site and location do not have the supporting infrastructure required for this size of development under this policy.

[20.BPC] The last paragraph in Area Delivery Plan Policy 1 states that;

"Open countryside - only appropriate limited development in the countryside will be allowed, focused on addressing identified needs and maintaining a strong rural economy."

[21.BPC] The proposal, as it currently stands, is outside the existing settlement boundary and pattern; therefore development should be strictly controlled and in this case avoided. Development should be d irected to the urban areas that have the infrastructure and facilities to support sustainable growth.

[22.BPC] West Berkshire's Local Plan (the Core Strategy); pages 39-40

Area Deliv á'ry Plan Policy 6 The East Kennet Valley

Environment

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¥ The character of all the settlements in this area will be conserved and enhanced by ensuring that any development responds positively to the local context. Conservation Area Appraisals will be carried out in accordance with the Council's programme.

¥ The environmental and leisure assets, including the river and its floodplain, the canal and the boating lakes will be conserved and enhanced, and development in the open countryside will be strictly controlled.

[23.BPC] Area Delivery Plan Policy 6, paragraph 5 under Environment, clearly states that the area would be conserved and enhanced by ensuring that any development responds positively to the local context. The proposal does not respond positively in the local context, its potential to change the characters of Burghfield Common, Sulhamstead and Ufton Nervet is radically for the worse with 129 houses being proposed, with a potential for further development later.

[24.BPC] Referring to West Berkshire Local Policies;

waDC Local Plan 1991- 2006 Saved Policies, page 6

POLICY OVS.1 - Overall Strategy

The Council will follow the existing settlement pattern and hierarchy found within the district area in seeking sustainable locations for development which minimise the need to travel and with appropriate access to public transport services and other community facilities. In this context the Council would prefer to see the redevelopment of brownfield sites (land previously developed) than the use of 'greenfield' (undeveloped) land.

[25.BPC] The proposed site is in open countryside and not considered as a "brownfield" site. Additional traffic would be created due to the lack of public transport along Hollybush Lane. This is in contravention of this policy and ENV.18 below.

POLICY ENV.18 - Control of Development in the Countryside, page 41

The nature and scale of development in rural areas should seek to encourage and sustain balanced rural communities. Development outside of settlements, allocated sites and other defined areas (Local Plan policies HSG.1, HSG.5, ECON.1, ECON.6, ECON.7, ECON.9, TRANS.3, and ENV.27 refer) will be permitted only where:-

(a) it will benefit the rural economy in accordance with Structure Plan policy C2 and Local Plan poliCies ENV.16, ENV.19 and ENV.20; or

(b) it will provide beneficial use of a brownfield site in accordance with Structure Plan policy aU3 and Local Plan policies OVS.1, and OVS.2; or

(c) it is within the permiSSible categories of housing development in the countryside; and provided it will maintain or enhance the environment and is appropriate in scale, form, impact, character and siting to its location in the countryside.

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[26.BPC] Referring to West Berkshire's Local Plan (the Core Strategy); page 71

Policy CS 13 Transport Development that generates a transport impact will be required to:*

¥ Reduce the need to travel.

¥ Improve and promote opportunities for healthy and safe travel.

¥ Improve travel choice and facilitate sustainable travel particularly within, between and to main urban areas and rural service centres.

¥ Demonstrate good access to key services and facilities.

¥ Minimise the impact of all forms of travel on the environment and help tackle climate change.

¥ Mitigate the impact on the local transport network and the strategic road network.

¥ Take into account the West Berkshire Freight Route Network (FRN).

¥ Prepare Transport Assessments/Statements and Travel Plans to support planning proposals in accordance with national guidance (70).

*Development proposals may not need to fulfil each bullet point. The supporting text below clarifies the types and scale of development which will be required to meet the specific parts of this policy.

[27.BPC] WBDC policy CS13 therefore takes a similar line to National Government policy. This proposal offers a repeat of those policies with no real or substantive solutions to those policies. Repeating the Government's mantra of reduction oftravel by car is not a solution, it is highly likely to increase traffic into the village as a whole, contrary to the wishes of the residents of both the Parish and Government.

[28.BPC] As highlighted in WBDC Policy CS13 above, first highlighted line, "Improve and promote opportunities for healthy and safe travel", Burghfield Parish Council has serious concerns in relation to the safety of pedestrians, especially pupils at the nearby Willink Secondary School. Increasing road traffic within the immediate area cannot be considered as an opportunity or promotion of healthy and safe travel. Burghfield Parish Council does not consider this proposal as being consistent with National and Local policies.

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