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TRANSCRIPT
BRACKNELL FOREST BOROUGH COUNCIL LDF
Representations to the Site Allocations DPD Submission Document
Prepared by Boyer Planning on behalf of Luff Developments Ltd March 2012
Representations to Bracknell Forest LDF | Site Allocations DPD Nov 2011
Contents
1. Introduction ................................................................................................ 1
2. Planning Policy Background and Development Requirements ............ 3
Regional Context ................................................................................................... 3 The South East Plan (May 2009) ....................................................................... 3
Local Context ........................................................................................................ 3 Bracknell Forest Council Core Strategy (Feb 2008) ........................................... 3 Bracknell Forest Council Draft Submission Site Allocations DPD (Nov 2011) .... 4
Draft National Planning Policy Framework (NPPF) ................................................ 5
3. Review of SADPD Proposals .................................................................... 7
4. Summary and Conclusions ...................................................................... 9
Appendix
Appendix one – sample heading
Appendix two – sample heading
1. INTRODUCTION
1.1 These representations have been prepared by Boyer Planning Limited on behalf
of Luff Developments Limited in respect of the Bracknell Forest Draft Submission
Site Allocations Development Plan Document (SADPD) consultation. Our clients
are leading the development proposals for the Land at Blue Mountain, Binfield,
which is the land within proposed Policy SA7 of the Site Allocations DPD. Luff
Developments are working closely with Bracknell Town Football Club to promote
a mixed use development comprising residential development, educational
facilities, the relocation of the football club and related open space.
1.2 Our representations seek to address the Draft SADPD and consider the detail of
the proposed policy associated with regard to the development of the Land at
Blue Mountain, Binfield, in order for the site to best meet the future development
needs of the town.
1.3 To summarise, in our opinion, the site at Blue Mountain provides the following
benefits : -
The delivery of at least 400 residential units, including affordable housing, with
the potential for up to 900 dwellings in the future;
The delivery of new educational facilities, including a primary school,
secondary school and Special Educational Needs facility;
The re-location of Bracknell Town Football Club to the site and provision of a
new training ground and facilities;
The opportunity for the sharing of sporting infrastructure between the
schools/education facilities and the football club, allowing a wider community
use for the public;
Areas of land for SANGs, which, combined with public open space, would
enable a sensitive disposition of built and open land uses;
Good access to bus services and dedicated cycle network, and further
detailed work and investment will be considered in relation to the improvement
in public transport, pedestrian access and cycling;
Close proximity to employment areas on the Western Industrial Area; and
The land is in single ownership and is available to start delivering the homes
and other facilities following the grant of planning permission;
The proposal has the additional advantage of releasing the existing Football
Club site at Larges Lane for housing development.
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1.4 The particular matters which this response addresses focus on include the
following : -
The development requirements of the Borough set within the context of the
planning policy background;
A review of the principal development proposals, including Blue Mountain in
the light of the above;
Our summary and conclusions.
2. PLANNING POLICY BACKGROUND AND
DEVELOPMENT REQUIREMENTS
Regional Context
The South East Plan (May 2009)
2.1 For the purposes of the Statutory Development Plan for Bracknell Forest, the
South East Plan remains part of the plan. However, we note that the Council
maintains a level of housing development in the Borough based on its Core
Strategy target of 10,780 new dwellings from 2006-2026. The South East Plan
provision for the Borough is 12,780 new dwellings from 2006 2026.
2.2 On the basis that the South East Plan remains in place at the time of the
forthcoming Examination into this DPD, with the Inspector's agreement, we would
wish to address this issue as part of our potential participation in the
Examination.
Local Context
Bracknell Forest Council Core Strategy (Feb 2008)
2.3 The planning vision for Bracknell Forest is set out in the Core Strategy and some
relevant extracts are below:
“The Borough will continue to grow sustainably, in a planned manner, with new
development being directed to sustainable locations and having good access to a
range of local facilities, services, housing and employment. New development will
be located so as to maximise the opportunity to travel by all modes and to
improve relative accessibility for all. New development will be mindful of the
character of the area in which it sits and will be designed and located such that it
will enhance the quality of life in the Borough.
There will be a continuation of development both within settlements, where
appropriate, and outside settlements through planned longer term expansion..…..
New housing will be targeted to meet the needs of local people and will include a
mix of tenures, size and types of unit. New communities will be planned to
provide the necessary physical infrastructure (e.g. roads, water) as well as the
social infrastructure (e.g. schools, libraries, leisure facilities, health facilities) to
support the community”.
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2.4 As part of the Core Strategy major locations for growth have already been agreed
at Amen Corner and Warfield. The proposed development at Warfield is to the
east of Blue Mountain. However these major locations will not be sufficient to
meet the Council’s requirements to 2026.
Bracknell Forest Council Draft Submission Site Allocations DPD (Nov 2011)
2.5 Bracknell Council has completions and allocations for 7,316 dwellings, at 30th
September 2011. This figure is derived from the Council’s housing allocation in
their Core Strategy and takes account of those units already built, with planning
consent, or within the Major Locations for Growth already identified in the Core
Strategy. The figure of 10,780 homes remains the basis for the SADPD, the
balance of homes to be identified on additional sites is 3,464 dwellings.
2.6 The housing completions and commitments to date set out in the SADPD are as
follows;
Net dwellings
Completions during the period 2006-2011 1,984
Homes with planning permission at 30th Sept 2011 2,437
Homes accepted in principle and at Amen Corner and Warfield 2,926
Remainder to be found 3,464
2.7 The Council consider that, taking into account windfall sites, small edge of
settlement sites and land in existing settlements, the remaining number of
dwellings which need to be identified on extensions to Bracknell or other large
settlements is 2,070.
2.8 The Annual Monitoring Report December 2011 (AMR) states that the Council do
not currently have a 5 year housing land supply, and so in addition to allocating
land for development over the next 20 years, it is also considered a priority to
identify sites which are deliverable in the short term to fulfil the 5 year housing
land supply as required by PPS3.
2.9 The housing land supply figures are detailed below:
Completions during the period 2006-2011 1,834 net dwellings
Deliverable supply 2,193
Requirement over the next 5 years 2,980
Supply 3.7 years
2.10 We note that the AMR contains a different completion figure for the same period,
2006 – 2011, compared to the SADPD. It has lower completions. We assume
that the most up-to-date figure is contained in the AMR. We also note that the
figure for deliverable supply in the AMR is lower than the figure for homes with
planning permission in the SADPD. If the AMR contains the correct figures, the
required amount of land to be allocated for housing may be greater than
envisaged in the SADPD.
2.11 Specific deliverable, available, suitable and achievable sites are needed for the
first 5 years (2012-2017) and specific developable sites for the following 5 years.
As completions over the period 2006-2011 have been considerably below target,
the need to provide additional housing numbers has been compounded and there
is added urgency to ensuring delivery of housing sites as soon as possible.
2.12 It is therefore considered important that the Council not only identify sites to
come forward for development over the next 20 years, but identify particular sites
which are able to come forward over the next 5 years in order to contribute
towards meeting the 5 year housing land supply.
2.13 Para 54 of PPS3 requires that local planning authorities should identify sufficient
specific deliverable sites to deliver housing in the first five years. These should be
available, suitable and achievable. To be considered developable, site should be
in a suitable location for housing development and there should be a reasonable
prospect that the site is available for, and could be developed at the point
envisaged. As we note in our comments in relation to Policy SA7 in the following
section, the site at Blue Mountain meets these criteria.
Draft National Planning Policy Framework (NPPF)
2.14 The Government published the draft NPPF on 25th July 2011. This will, in large
part, replace the existing raft of government planning policy statements. We
consider that it is a material consideration, although it is not yet formal
Government policy. It includes, with more detail, the broad themes set out in
earlier Government announcements referred to above. For example, it highlights
the presumption in favour of sustainable development at paragraphs 13-18. In
respect of housing, paragraph 109 sets out a range of measures to significantly
increase the supply of housing. Paragraph 110 states that applications should be
considered in accordance with the “presumption”.
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2.15 Of particular relevance is the following requirement for local planning authorities,
set out at para 109 of the NPPF:-
“Identify and maintain a rolling supply of specific deliverable site sufficient to
provide five years’ worth of housing against their housing requirements. The
supply should include an additional allowance at least 20% to ensure choice and
competition in the market for land”.
3. REVIEW OF SADPD PROPOSALS
3.1 We continue to support the Council’s approach in identifying sites outside of the
current settlement boundary in order to provide housing in the Borough over the
next 20 years. In particular, we support the allocation of Land at Blue Mountain,
Binfield for a mixed-use development, as shown at Map 35 of the SADPD. Our
comments focus on the details of the wording of Policy SA7, the supporting text
and Map 5: Illustrative Concept Plan.
3.2 We are pleased to see that the Council has amended the wording with regard to
the phasing of the Land at Blue Mountain in paragraph 2.4.17 and recognise that
the delivery of this site is crucial in terms of providing the land for a new
Secondary School which will facilitate other development within the area. Due to
the critical nature of the school capacities in the area, it is understood that only a
very limited amount of development will able to come forward before the school
at the Blue Mountain site is completed. It is therefore vital that the development
at Blue Mountain is deliverable as soon as possible following the adoption of the
SADPD. The revised delivery commencement of 2014/15 reflects the strategic
importance of this site.
3.3 We have submitted representations previously on behalf of Luff Developments
promoting the site as being able to accommodate up to 900 dwellings. In physical
capacity terms, this remains the case, however through discussions with the
Council we understand that at the present time, only 400 dwellings are required
on the site. In order to retain the potential for development of the remaining 500
units in the future, we consider that the Illustrative Concept Plan for Land at Blue
Mountain (Map 5) should be amended with regard to the land on the eastern side
which is currently shown as ‘other open space’. The site is already providing a
considerable amount of space for use as SANGS and Public Open Space, and
therefore the land on the eastern side of the site is not required to be designated
as additional open space, and indeed it will not be offered as such by Luff
Developments. Alternative suggestions as to how this land may be designated
include the following options;
Colour white with a blue line and marked ‘other land under the control of Luff
Developments’;
Indicate as a ‘reserve site for future housing’ and mark in another colour.
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3.4 As stated in our representations to the Preferred Options SADPD, if the Council
wish to allocate only 400 units on the site, a revision to the extent of the
development area should be made. This would be on the basis that 400 units
would support 924 residents (based on the average occupancy rate of 2.31
persons per dwelling taken from para. 1.45 of the Limiting the Impact of
Development SPD, 2007). This level of population would require 7.4ha of
SANGS land based on the requirement of 8ha per 1,000 population and 4ha of
public open space at 4.3ha per 1,000 population, totalling 11.4ha. The concept
plan in its current form provides around 14.5ha of public open space and SANGS
land which is in excess of the policy requirement. The landowner would retain the
balance of land which is not required in connection with the development.
3.5 With regard to the policy wording, an additional land use has been identified for
the site since the publication of the Preferred Options SADPD; a ‘multi-functional
community hub’. No justification has been put forward for this additional
requirement which will inevitably require additional land. A further new
requirement under the infrastructure list is for an ‘on-site waste recycling facility’.
Again, no justification has been provided in support of this addition, and
discussions should be held between the Council and Luff Developments
regarding this requirement.
3.6 The policy wording includes detailed reference to infrastructure required to
support the development, however the policy does not make clear whether these
requirements are all expected to be provided by Luff Developments, or whether
other developments in the vicinity of the site will be subject to S106 requests for
financial contributions towards the infrastructure requirements. The mechanism
for securing the requirements should be clarified within the policy wording.
3.7 Luff Developments will continue to provide supporting information for the site,
including any environmental and technical work necessary to support the
proposals. We request that the Council continue to work with Luff Developments
in bringing forward the Land at Blue Mountain for a mixed-use development.
4. SUMMARY AND CONCLUSIONS
4.1 Our clients, Luff Developments Limited, are leading the development proposals
for the Land at Blue Mountain, Binfield, which is the subject of the proposed
allocation in Policy SA7 of the Site Allocations DPD. Luff Developments are
working closely with Bracknell Town Football Club to promote a mixed use
development comprising residential development, educational facilities, the
relocation of the football club and related open space.
4.2 Our representations seek to address the Submission SADPD and consider the
detailed proposals for the site in the light of the Council’s vision, and our client’s
interests. The SADPD should have regard to addressing the future development
needs of the Borough in the most sustainable way and in accordance with the
Council’s vision set out in its Core Strategy.
4.3 If the South East Plan is part of the development plan at the time of the
Examination into the SADPD, with the Inspector's agreement, we would wish to
address the issue of the “housing requirement” for the Borough as part of our
potential participation in the Examination. Based on the Core Strategy housing
requirement, the SADPD needs to identify sites outside of the current settlement
boundaries to accommodate 2,070 dwellings by 2026. In particular, the Council is
currently unable to demonstrate a 5 year supply of housing land, and so needs to
identify specific deliverable, available, suitable and achievable sites for the next 5
years.
4.4 The land at Blue Mountain is suitable for development, available now and
therefore a significant element of the housing development can be delivered
within the next 5 years. The site has the capacity to provide up to 900 dwellings
which would help the Council to deliver its 5 year housing target. This is
achievable whilst retaining the important gap between Bracknell and Binfield.
4.5 In addition to the provision of new residential units on the site, our client has
agreed to deliver new much-needed educational facilities on the site and also to
provide land for the relocation of Bracknell Town Football Club, a use which will
be complementary to the provision of education facilities on-site through the
sharing of sporting infrastructure. This has the additional advantage of releasing
the existing Football Club site at Larges Lane for housing development. These
proposals together provide an excellent opportunity to create a high quality,
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sustainable mixed-use urban extension to Bracknell which will provide facilities
for local people.
4.6 The policy wording includes detailed reference to infrastructure required to
support the development, however the policy does not make clear whether these
requirements are all expected to be provided by Luff Developments, or whether
other developments in the vicinity of the site will be subject to S106 requests for
financial contributions towards the infrastructure requirements. The mechanism
for securing the requirements should be clarified within the policy wording.
4.7 In summary, our clients, Luff Developments Limited, are able to bring forward a
comprehensive development strategy for the Land at Blue Mountain, in close
consultation with the Council and its stakeholders, which would deliver housing,
educational and sporting facilities and associated infrastructure and open space.
We are supportive of the proposed allocation at Blue Mountain in principle, but
consider that some of the additional requirements, such as a community hub and
waste recycling centre, need to be reviewed in discussion with the Council, and
further discussions need to take place with regard to the additional land available
but which the Council considers is not required for further housing development
to take place.
Boyer Planning Ltd
March 2012
Crowthorne House Nine Mile Ride Wokingham Berkshire RG40 3GZ01344 753 220 01344 753 221