LPU Public Consultation: CPRW Template Response for Opposing Development in the Green Belt

Consultation Deadline: 4pm 22nd February 2019
Please read on for our template response and alternative methods of responding – it’s a long post! We hope that most people will by now have received the “Homes for the Future” brochure from WBC which was delayed before Christmas. As promised, CPRW’s planning experts have prepared a suggested template for those who want to complete the LPU public consultation and oppose development in the Green Belt. We have prepared a LPU Response Form which you can download in whichever format works best for you LPU-Response-Form-WORD, LPU-Response-Form-PDF or LPU Response Form PAGES, to which you can add your name and address, and edit/complete as you wish. Our response to the relevant questions is also published here in full, which can be copied and pasted into the online survey or into an email. We will be distributing the same advice on printed leaflets. You can return your comments to WBC by post, email or on their online form, and you do not need to answer all the survey questions. Please supply your first and last names, address and postcode whichever method you use to respond.

 

Of course you are entirely free to enter your own response and comments. We felt that the CPRW focus should be on resisting the principle of Green Belt release at Ruscombe so we have not included comment guidance on other sites and issues. We recognise that views may differ on the appropriateness or otherwise of smaller sites in the area so you may wish to comment further in response to questions 29 and 30. And you can of course comment on all other questions in the survey if you have views on them.

 

Our response relates to the general question of siting new developments (Q2) and the section focusing on the Northern Area (Q28, Q30) which WBC has identified as the villages of Twyford, Hurst, Charvil, Sonning, Wargrave and Remenham, and the surrounding countryside. The Northern Area includes all of the Green Belt in Wokingham Borough.

 

RESPONDING ONLINE
• You can find all of the documents and the online survey form via the links on the Council’s website. If you wish to use our comments they can be copied below and pasted into the relevant boxes:
www.wokingham.gov.uk/localplanupdate

 

RESPONDING BY POST
• Paper copies of the form are available from the Council’s offices at Shute End.
• You don’t need to use the form – you can use plain paper or print off our document in whichever format works best for you LPU-Response-Form-WORD, LPU-Response-Form-PDF or LPU Response Form PAGES but do make sure to supply your full name, address and postcode for your comments to count.
Post to Growth & Delivery Team, Wokingham Borough Council, Civic Offices, Shute End, Wokingham, RG40 1WR

 

RESPONDING BY EMAIL
• Comments may be emailed – please send your comments, referencing the relevant survey questions, along with your full name, address and postcode.
Email to LPU@wokingham.gov.uk


CPRW TEMPLATE RESPONSE TO Q2, 28 & 30

 

Survey Question 2
Where in the borough are the best opportunities to establish new communities which include such things as local centres, schools and improved sustainable transport links? Please provide details and outline the reasons why

 

CPRW Response to Question 2
Firstly, it should not be assumed that new communities should accommodate all the Borough’s housing requirements.  Sites will exist, within or adjacent to settlements, that whilst not forming part of a new community may still be appropriate for development.

 

With regards the location for potential new communities, careful consideration needs to be given to national policy set out in the NPPF, which includes guidance upon Green Belts, a notable constraint upon development in the northern most part of Wokingham Borough.

 

The NPPF makes it clear that amendments to the Green Belt should only be undertaken in exceptional circumstances.  Given that Wokingham Borough consists of a small proportion of Green Belt land (16%), it is apparent that exceptional circumstances will not be present to introduce a new community in to the Green Belt in this instance, because 84% of the Borough is not subject to such constraint, and will therefore be better placed to accommodate such a scale of development.

 

The Council have been presented with a number of options for generating new communities across the Borough, the majority of which do not lie within the Green Belt.  It therefore follows, in specific response to the question, that the best opportunities to establish new communities will be on non-Green Belt land in the Borough.


Survey Question 28
Are there any locations in the ‘Northern Area’ which you feel are suited to being more flexible with building heights and development densities? Please provide details and outline the reasons why.

 

CPRW Response to Question 28
The villages in the northern area are characterised by two storey development and typically don’t contain high density development at present. Densities beyond those which currently exist may therefore damage the established character that is present.


Survey Question 30 
Do you have any comments on any of the promoted areas of land in the area? Please include site references where appropriate. 

 

CPRW Response to Question 30
I object strongly to any potential development of the following sites:
5RU001, 5RU002, 5RU003, 5RU004, 5RU005, 5RU006, 5WA007

 

It is clear from the Masterplanning document that if development is to be supported by the Council it would consist of several, if not all, of the above promoted sites. It is identified in the Wokingham Strategic Growth Locations Report (June 2018) as a potential strategic development opportunity for anything between 500 and 3,500 homes.  Development of such scale would have a substantial detrimental impact upon the local environment, in terms of appearance, character, heritage and general amenity, all of which contribute to why we have chosen to live in the area.

 

The Report suggests that traffic levels at Twyford’s village centre crossroads could be reduced through major new road infrastructure, building a new by-pass, including an additional rail crossing.  While the Twyford crossroads may suffer from congestion at peak times, this does not warrant the introduction of strategic scale development.  The introduction of thousands of houses, and traffic generated by them, will add congestion to a much wider area, and whilst potentially enhancing one specific junction would result in considerable detriment to many others.  As a result, an improved cross roads junction definitely does not justify strategic scale development as proposed through the above sites.

 

The Report identifies a number of other enhancements that could take place as part of strategic development proposals, such as improved parking at the rail station, and the provision of community facilities.  Whilst such improvements might be welcome, it is strongly considered that they can occur without strategic scale development and are therefore most definitely not a reason to justify it.

 

All of the above sites lie within land designated as Green Belt.  The National Planning Policy Framework confirms that any changes to Green Belt boundaries (as would be needed to enable strategic scale development) can only take place in exceptional circumstances.  It also requires the Council to fully examine all other reasonable options for development, before amending Green Belt boundaries.  Given that 84% of Wokingham Borough is not subject to Green Belt designation, it is strongly considered that there will be other reasonable options to accommodate the Borough’s development needs without needing to amend Green Belt boundaries, and therefore exceptional circumstances are not present.  Development of the above sites would therefore be in direct conflict with National Planning Policy.

 

In further defence of the retention of the established Green Belt at Ruscombe, the Council’s recent Green Belt Review, concluded that no areas merited removal from the Green Belt.  This was because all parcels were shown to contribute, or significantly contribute, to the purposes of the Green Belt, underlining why development upon them is not justified.

 

For these reasons I strongly object to the potential development of the above sites.