Winnersh Plant Hire is on Reading Road, not far from the Showcase roundabout. In the previous draft of the housing sites for the new Local Plan, the council decided it was suitable for 20 houses. In the latest version, they have decided it can take 85. That’s quite a leap – and one which I disagree with. Here’s what I said in my response to the consultation.

I disagree with the proposal to extend the number of units from 20 to 85

When discussing this site, the Sustainability Appraisal says

No explanation is provided in the Sustainability Appraisal itself as to the reasons for the very significant increase in the identified capacity of the site.  Nor is there any information in the Revised Growth Strategy to explain it.  The explanation is only given in the Non-strategic Sites Report, referred to in paragraph 5.4.71 from the Sustainability Appraisal reproduced above.  Similar wording occurs elsewhere in the Sustainability Appraisal.

Regrettably, the Non-strategic Sites Report was not among the documents provided for the public in order to inform their responses to the Revised Growth Strategy consultation.  Residents wishing to contest the revised allocation are therefore at a considerable disadvantage, as they do not have access to the information they need in order to know what to address in their responses.  That includes information on flood risk, indicative layouts and types of dwelling, and reduced parking.  In my opinion, this makes the consultation on this site invalid.

As a councillor, I was able to use my contacts in the council to gain access to this unpublished report, and my comments on the site do take it into account.  The main issues I wish to comment on are flood risk and parking, and I query the amount of the site which is actually developable for housing.

The Sustainability Appraisal, in paragraph 5.4.71, quoted above, notes that the site is located in flood risk zone 2.  The table of sites under Appendix J: Development Guidelines in the Revised Growth Strategy says of Winnersh Plant Hire on page 123  “Development should avoid area of high flood risk”   Only in the detailed discussion of the site on pages 32-33 in the Non-strategic Sites Report – not available to the public in the consultation – is it mentioned that part of the site is actually in flood zone 3.  The table that assesses the sites against the sustainability criteria on page 176 of the Sustainability Appraisal scores this site as RED for fluvial flooding and AMBER for surface water flooding.  It floods regularly. 

The National Planning Policy Framework makes it clear that development should not be taking place in areas at high risk of flooding, and that sequential and exception tests are required to permit it.  It is necessary to demonstrate that the risk of flooding on the site or elsewhere can be mitigated before development can take place. 

Yet the need for mitigation is not mentioned in the development guidelines in Appendix J.  And all that is said in the Non-strategic Sites Report is “Flood risk management scheme will take site out of flood zone 2.”  It does not say how that will be achieved, when the sites on either side of Winnersh Plant Hire are also in flood zone 2, and does not say anything about the part of the site in flood zone 3.  No flood management scheme is described. 

While I accept that this is a brownfield site, only part of it currently has residential development on it, and much of the site is currently an open yard.  An allocation of 20 units, as originally proposed, would leave land available for flood mitigation measures.  Could flood mitigation measures be achieved with an allocation of 85 units?  I think it is incumbent on the council to demonstrate that it is possible to mitigate against flooding before increasing the allocation to 85.

The Non-strategic Sites Report looks at two options for increasing the capacity of the site.  As previously mentioned, these are on pages 32 and 33.  One option is for 84 dwellings, the other for 91.  85 is the number specified in the Revised Growth Strategy. 

When looking at the constraints on the site, the Non-strategic Sites Report mentions the fact that high voltage overhead cables go through the site.  The need to avoid developing the area under the power cables is mentioned in the development guidelines in the Revised Growth Strategy.  However, the Sustainability Appraisal does not appear to have any mechanism for assessing the impact of high voltage overhead cables on the suitability of a site.  This appears to me to omit a relevant factor for the evaluation of sites. 

The main difference between the two options modelled for the site in the Non-strategic Sites Report is that the one with the higher number of dwellings includes 7 houses very close to the line of the overhead cables.  This is clearly not acceptable.  However, as no justification is provided for the choice to allocate 85 dwellings to this site, it is unclear whether it is the proximity of housing to the overhead cables that led the council to reject the option which had 91 dwellings.

The 2 options for the Non-strategic Sites Report both rely on sub-standard parking provision.  The report says page 32 under “Challenges”  “> Car parking provision – provide reduced car parking standards”

Option A has

58 unallocated parking spaces for 58 1 and 2 bed flats

10 allocated and 4 unallocated parking spaces for 10 3 bed flats

16 allocated and 11 unallocated parking spaces for 16 3 bed houses

5 visitor spaces – all allocated in the table against the 3 bed units

Total 104 spaces for 84 units

According to the council’s Parking Demand Calculation Sheet available at https://www.wokingham.gov.uk/planning-policy/planning-policy-information/evidence-topics/  104 spaces is the requirement without any visitor parking.  With visitor parking calculated at 0.2 spaces per allocated space, the shortfall is 5 spaces.

Option B has

58 unallocated parking spaces for 58 1 and 2 bed flats

10 allocated and 4 unallocated parking spaces for 10 3 bed flats

23 allocated and 16 unallocated parking spaces for 23 3 bed houses

7 visitor spaces – all allocated in the table against the 3 bed units

Total 118 spaces for 91 units.

According to the council’s Parking Demand Calculation Sheet available at https://www.wokingham.gov.uk/planning-policy/planning-policy-information/evidence-topics/  118 spaces is the requirement without any visitor parking.  With visitor parking calculated at 0.2 spaces per allocated space, the shortfall is 7 spaces.

Although this site is within walking distance of a railway station and there is a bus service on Reading Road, planning a site on the basis of no allowance for visitor parking at all is short-sighted.

The layout of the parking is also questionable.  It is similar in both options, in that two parking courts are identified for the flats which are to be at the front of the side, and then some parking spaces are provided further into the site for the houses which are also further back.  In the 84 unit option, none of of the parking spaces for the houses are located next to the houses;  in the 91 unit option, a few appear to be. 

In order to fit the houses on the site, both options have an access road that leads to the back of the site, with a block of parking spaces at the end of the access road.  This block of parking appears to be located in or on the very edge of the part of the site that is in flood zone 3, and certainly the access road to reach it goes through flood zone 3.  Having parking that is susceptible to flooding or can only be reached by a road that is susceptible to flooding, does not take flood risk properly into account. 

Like the assumption that no visitor parking is needed, this parking layout is also short-sighted, not just from the point of view of flooding, but also because where parking spaces are located away from houses instead of directly in front or to the side of the dwelling, the evidence is that residents opt not to use them, and park on the road in front of their house instead.   The layout of the parking is therefore a problem, as well as the lack of visitor spaces.  The indicative layouts leave very little ability to find more or better space for parking.

In both options, some houses appear to be extremely close to the area of the site which is in flood zone 3.   The flats at the front of the site appear to have no access to any amenity space, and the other flats only appear to have limited amenity space.  The open space on the site is limited to that directly under the power lines and partly in flood zone 3.  It is unclear how the flats would be configured, but it seems likely that in order to fit a total of 68 flats into the 3 blocks, they would be required to be at least 4 storeys high, which is considerably higher than other residential development around that site.  All of these things suggest that 85 dwellings is too many.

The access proposed is off Reading Road.  This is also likely to be problematic for 85 dwellings, whilst quite possibly being acceptable for 20.  This is because the point of access lies between a signalised pedestrian crossing and a bus stop layby, which are only a few metres apart, as can be seen in Figure 1.

Fig. 1

The final point about this site is that it does not include 576 Reading Road.  This is unfortunate, as it leaves that existing dwelling isolated and with the likelihood of being overlooked by a 4 storey block of flats next door.  If this property was able to be included it would create a site with a shape that would make it considerably easier to achieve sensible development on the site.

In summary, the council has not demonstrated that 85 units are achievable on this site without compromising planning policy guidelines, and therefore the increase from 20 to 85 is unjustifiable.  In addition, the information which makes this obvious has not been available as part of the consultation, and therefore the consultation on this site – and on the other sites dealt with in the Non-strategic Sites Report – is flawed.

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