by Prue Bray on 23 January, 2022
I have just sent in my response to the Wokingham Borough Local Plan Update Revised Growth Strategy Consultation. The Revised Growth Strategy now includes a Strategic Development Location of 4,500 residential units plus a business development area in the countryside next to Winnersh and Sindlesham, which I represent on the council. Here is what I have said about this particular bit of the Local Plan Update. Warning: it is ever so slightly ranty, while still trying to make points that planners have to consider….
I disagree strongly with the proposal to allocate this site for 4.500 units, of which at least 2,200 are to be built during the plan period. This site is not just proposed for housing, but also for the creation of substantial space dedicated to employment on top.
These comments are written from the point of view of Winnersh and Sindlesham and do not attempt to address the concerns of people in Arborfield or Shinfield, who I am sure also object strongly.
Whilst I object to the loss of green space and countryside, outrage will not make the proposal go away. Planning arguments might, and in that respect my concerns are about the deliverability of the vision for Hall Farm.
My first concern is overall capacity. I do not think there is anything in the Revised Growth Strategy that demonstrates that the volume of housing and the volume of economic activity can actually be delivered within the constraints of the SDL as shown.
I fear that despite the grand plans, what will actually happen is that we will end up with more houses than allocated, with the infrastructure being provided late or not at all, with the type of housing not meeting local need. It will come without the required affordable housing, be of poor build quality, with inadequate drainage, water supply and foul sewers. The landscaping will be left incomplete and residents will be abandoned to the mercy of management companies instead of being able to rely on amenity space, parks, lighting, drainage and roads that are built to – and maintained at – adoptable standards. This is broadly the experience of all the SDLS so far, and of all the larger developments in the Borough in fact. I see nothing here that will make Hall Farm any better.
I am not opposed to Strategic Development Locations in principle, as I believe they can deliver housing in a better way than piecemeal development, because the scale of the development permits infrastructure to be properly planned and provided.
However, over the period of the existing Local Plan, the council has shown itself to be incapable of ensuring that the infrastructure is provided in a timely way. Or, indeed, of ensuring that it is delivered at all in some cases. This makes me extremely sceptical about whether the promises of infrastructure laid out for Hall Farm / Loddon Valley in the policy at Appendix G of the Revised Growth Strategy will be kept, even if it is currently the council’s intention to keep them.
This is a site which includes the valley of the River Loddon, with part of the land needed for flood alleviation measures for the area around the Showcase roundabout, which are already known about. Major flood mitigation measures will be required. Not all those measures will be required as a result of the new development, because the flood alleviation scheme is known to be needed already.
In addition, in order to achieve any sort of viable access, a bridge across the M4 will be required. Policy SS3 in the Revised Growth Strategy also raises the possibility of a new junction onto the M4. Mole Road is a country road without proper drainage which will require a major upgrade in order to accommodate the volume of traffic that would use it.
An additional settlement ultimately equivalent in size to the current settlements of Winnersh and Sindlesham combined would generate considerable traffic which would need to use the B3030, the Winnersh Relief Road, and the Winnersh crossroads. Past modelling shows the junctions and roads already nearing, at, or over capacity, without any additional traffic from Hall Farm.
The cost of a new bridge over the motorway, a new motorway junction, a complete upgrade of Mole Road, changes to other junctions on the network, flood alleviation and so on, will be enormous. I haven’t even mentioned the impact on Arborfield Cross, Shinfield and junction 11 of the M4.
We have only to look at the fact that the roads promised for the existing SDLs are still not all complete to know that the challenges and costs for this new SDL are likely to make it impossible to deliver the highways and flooding infrastructure for Hall Farm at all, let alone in a timely way.
In addition to flood mitigation and roads, the Hall Farm policy promises 3 neighbourhood centres, with a range of retail (including food store of 2,500m2), leisure, including indoor and outdoor sports, cultural, health and service facilities and delivery of three primary schools (2 x 3 form entry, and 1 x 2 form entry) and one secondary school. (Revised Growth Strategy policy SS3), plus a huge range of measures for cycling, walking, open space, biodiversity, and public transport. Together with 35% affordable housing.
My question is: who will pay for this infrastructure? The cost is likely to far exceed any Community Infrastructure Levy contributions that come from the development itself. The government refused to fund the infrastructure deficit that was associated with Grazeley garden village. Why would they suddenly fund the infrastructure associated with this proposal, especially given that the site is even less sustainable than Grazeley was?
I believe the situation will be worse as regards infrastructure compared to the current SDLs. This is because the announced policy is to split the allocation into two, with roughly half in the plan period and half coming beyond it. The new Local Plan is intended to run until 2038. That means that only half of the housing that would justify the infrastructure laid out in SS3 would be delivered in the plan period. Which roads and junctions will be upgraded by 2038? How much of a secondary school or a primary school will get built, what sports facilities, what retail and what health provision? How many years will the people living in the SDL have to wait for the rest of it? 10 years? 20 years?
And then there is affordable housing. The Borough is crying out for affordable housing – and yet the council has failed to achieve the affordable housing target in the current Local Plan. Developers often argue viability prevents them providing all the affordable units they are supposed to under the policy. Why will this SDL be any different?
The policy does not indicate anything about what infrastructure should be delivered by the end of the plan period. In which case, how will the council will be able to insist that any planning applications based on the policy provide infrastructure up front or in any sort of timely way?
Furthermore, because half of the housing is scheduled for beyond the plan period, how do we know how much will ultimately be delivered? If the allocation increases after 2038, will the infrastructure also be able to increase? Or will we have another situation like Earley, which went without a much needed secondary school because there were no suitable sites left? If the number decreases or the build rate is slower, will it still be possible to get the promised infrastructure?
In summary, quite apart from the destruction of the countryside, and difficulties with flooding and roads, which make it a very inappropriate site in any case, the proposal for Hall Farm / Loddon Valley is fatally flawed in that in splitting the housing allocation between before and after 2038, it does not guarantee any infrastructure being provided within the plan period. Inadequate new infrastructure will have a considerable knock-on effect on the existing infrastructure and make development at Hall Farm / Loddon Valley unsustainable. Policy SS3 should therefore be reconsidered.Leave a comment