Local Plan Representations

THE COOKHAM SOCIETY

LOCAL PLAN PREFERRED OPTIONS CONSULTATION 2014

CONSOLIDATED REPRESENTATIONS

Local Plan section	Local Plan question no.	Society’s reference	Cookham Society’s representations
2: Spatial portrait		1 2	Comment: Section 2.3 does not recognise the proportion of population which will be of retirement age by the end of the period (2029) Comment: Section 2.4 has nothing to say about the arrival of Crossrail and its impact.
3: Vision and objectives	1	3	Comment: Insufficient attention to catering for the elderly who may make up to 25% of population by end of consultation period.
	2	4 5 6	Objective 1: no comment. Objective 2: no comment. Objective 3: no comment. Objective 4 is not being fulfilled because of the loss of more than 26 hectares of employment land (Comment). Objective 5: no comment. Objective 6 – Comment: There needs to be a ‘Plan B’ for those who cannot stay in their own homes. Objective 7: no comment. Objective 8: no comment. Objective 9: Comment: Do not deny the reality of greatly increased car ownership; i.e. allow for parking for Crossrail. Objective 10: no comment. Objective 11: no comment.
4: Strategy	3-4	7 8 9	Comment: The Strategy is deficient because it provides no correlation between the provision of jobs and the need for housing.  Para. 4.2.3 does not say what a ‘sustainable balance’ is/should be. Objection: The Strategy is deficient because it provides no correlation between the provision of jobs and the need for housing.  Para. 4.2.3 does not say what a ‘sustainable balance’ is/should be. The methodology used to evaluate the Green Belt in the Green Belt Purpose Analysis document is flawed in that it fails to recognise the reality of settlements washed over by the Green Belt and thus fails properly to address the purposes of the Green Belt in the NPPF. Comment: Para. 4.2.7 would be improved by the addition of: “.…recognising that preservation of the environment in some areas addresses an important social need – that of leisure and access to areas of environmental attractiveness".
	5		No comment
Community-led development	6	10 11	Comment on section 4.5.3: In this area any community led development would be unlikely to meet the requirement that it should not significantly increase the sales land value. Objection to Preferred Policy Option (PPO) BLP2: The criteria set out in PPO BLP2 are far too loose and need to be tightened up in order to protect interests of acknowledged importance.
5: Quality of place
Design	7	12	Support, subject to suggested amendments, as follows: (1) Insert in PPO PLA1 - proposed partnerships: new point 3: Qualified architects to ensure consistency of design where appropriate. and (2) add: Local communities will be encouraged to produce Village Design Statements to help achieve the aims of this PPO.
Maidenhead Town Centre	8	13	Objection to para. 5.1.6, PPO PLA1 and Question 8: The appropriate place for considering increased heights of buildings in Maidenhead Town Centre is through a review of the Area Action Plan.
Townscape and landscape	9	14	Objection to para. 3 of PPO PLA2: The Landscape Character Assessment was too broad brush to provide a meaningful assessment of development proposals.  This paragraph can be removed and the issue dealt with under PPO GBC 2.
Thames riverside corridor	10	15	Support Question 10, subject to addition of the following at the end of closing para. to PPO PLA3: “… and where they will not have an impact on the openness of the Green Belt”.
6: Green Belt and countryside character	11	16	Support para. 6.1.1, subject to the following modification: Add at end of point 4: “…provided that it is demonstrated that they are no longer required for agricultural purposes”.
Green Belt		17	Objection to PPO GBC1: Policy requires amendment in para 2  by addition of: “Where it is determined to the Council’s satisfaction that the need exists for Rural Exceptions Housing, the Council will give favourable consideration to the adjustment of Recognised Settlement boundaries to enable that need to be met”.
Minor adjust-ments to the Green Belt	12	18	Comment: Site ref. WMCO0012 in Rejected Sites - Housing Site Assessments: Land adjoining Lee Cottage, School Lane, Cookham does not serve any of the purposes of the Green Belt defined in the NPPF and does not reflect the boundary of the built-up area.  Recommend taking out of Green Belt and inclusion in settlement of Cookham.
		19	Comment: The Holy Trinity Church Paddock (Map1: Cookham) does not serve any of the purposes of the Green Belt defined in the NPPF and this site should be promoted as a Community Asset or Local Green Space and not included in the Green Belt.
Countryside character	13	20	Comment: PPO GBC2: Suggested replacement of 4th bullet point relating to supported types of development: “limited infilling in villages, and limited affordable housing for local community needs in Recognised Settlements (refer to…”.
		21	Objection to PPO GBC2. There is no mention of the previous policy concerning the Area of High Landscape Importance in the north of the Borough and this needs to be reinstated.
New residential development in the Green Belt	14	22	Objection to PPO GBC3 and Question 14. (1)   Suggested addition to Bullet Point 3: “…which is contiguous to the main dwelling and does not exceed ?% of the main dwelling”; (2)   Suggested addition to Bullet Point 4: “…provided that the ground floor area of the replacement dwelling exceeds the original by no more than ?%”; (3)   Suggested addition to bullet point 5: "..which should be contiguous to the Recognised Settlement boundary".
Re-use and replacement of non-residential buildings in the Green Belt	15	23	Comment:  Note: para. 6.4.3. The permission only partly expires in 2016 AMEND  PPO GBC4 In heading and first sentence take out "replacement".  Insert in first line after “..replacement of buildings” “for business or industrial use…”.  Reason: Otherwise it does not appear to prevent the replacement of agricultural buildings with houses. First bullet point should be longer than 4years. There should be a strict test for redundancy before change of use is allowed together with a withdrawal of permitted development rights for new agricultural buildings on the entire holding. OBJECT to PPO GBC4 for reasons set out above.
Major developed sites in the Green Belt	17	24	Agreed
7. Housing Amount and distribution of housing	18	25	Object to PPO HOU1, supporting paras and Question 18 1.      The sum of the figures in Table 3 does not match the total in Table 2. 2.      The number of dwellings specified for Cookham in Table 3 is unachievable. 3.      The Borough’s estimated supply from windfall (1,778) is not likely to be achieved 4.      There is no consideration of whether phasing is desirable. A more robust assessment of supply is required. The Borough should have considered a more strategic approach to meeting housing need; e.g. the identification of a new ‘township’, before adopting the current approach of chipping away at the Green Belt.
Allocated housing development sites/sites in the Green Belt	19/20	26	Object to Table 6 and Question 20. Area west of Whyteladyes Lane, Cookham. (a) The methodology used In Green Belt Purposes Analysis document is flawed in that it fails to give weight to nearby settlements which are ‘washed-over’ by the Green Belt. (b) Development here would reduce the separation between Cookham Rise and Cookham Dean, and has been recently rejected on appeal (see appeal ref: APP/T0355/A/13/2206932)  (c) Thames Water has noted that further development cannot be sustained without upgrading the sewers.  This is unlikely to occur for many years because of the scale of upgrade required. (d) The site is crossed by 2 major gas mains, which would be expensive to relocate. (e) There is a Source Protection Zone in the locality which needs to be protected. (f)    There would be no obvious benefit to the local community for development here. Area around Spencer’s Farm, Maidenhead (a)  Development of this site would represent an unacceptable incursion into the Green Belt within the narrow gap between Maidenhead and Cookham. To provide a proper access to this development would be very difficult.  Because of the proximity of the railway, it is very difficult to access the site from the west and no obvious alternative access points can be provided either without major road construction in a south-easterly direction or through the Aldebury Road estate, whose road layout has not been designed for 500 extra dwellings and would result in an unacceptable loss of amenity for exiting residents.  2 accesses would be required.  Proper servicing of this land would require the construction of a new road between Cookham Road and Sheephouse Road.  Recent aerial photography suggests the extent of future flooding is likely to be greater than previously predicted (see attached photograph looking north from Lutmans Lane).
Meeting a range of housing needs	22	27	Object to PPO HOU3 and Question 22.  We support the principle of meeting a range of housing needs, but we strongly object to the final para. of PPO HOU3 and paras. 7.3.6 to 7.3.8.  It appears to us from the briefing held in Cookham on 11th February that the Borough does not distinguish between Residential Care and Nursing Homes.  It is accepted that it is desirable, as far as possible, that the elderly should be able to be cared for in their own homes; however, this is not suitable for all. It has to be accepted that an ageing population will increase the need both for care homes and for nursing care and the local plan should allow for these types of provision so that the elderly can be looked after close to friends and family and not forced to go outside the Borough.
Affordable housing	23	28,29,30	Object to para 7.4.5. The para. should be re-written to make clear (a) it is referring to Rural Exceptions Sites, and (b) RE sites will only be permitted in Recognised Settlements.  Otherwise there could be sporadic ‘RE’ housing anywhere in the Green Belt. Object to PPO HOU4.  We have no problem in principle about the reduction in affordable housing thresholds.  However, the Borough has not demonstrated what effect this reduction will have on windfall sites, which we believe will result in a reduction of about 35% in windfall housing. The thresholds should be regarded as the maximum requirement allowing for a degree of flexibility in application. Object to PPO HOU5.  Suggest inclusion of an additional bullet point: “h.  New Rural Exceptions Housing will only be acceptable within Recognised Settlements”.
Affordable Housing – shared equity	24	31	Object to Question 24.  This question implies that the Borough will seek to prefer Shared Equity or Shared Ownership over affordable rented housing.  However, a large proportion of those in need of affordable housing are unable to afford these two types of tenure.
Affordable Housing – Rural Exception sites	25	32	Object to Question 25 (for reasons set out above).
Protection of residential land and the housing stock	27	33	Support
Housing layout and design	28	34	Object to PPO HOU8. A further bullet point should be added:  “In residential estates dwellings should be laid out in such a way as to ensure surveillance and assist in crime reduction”. Support Question 28, subject to the amendment proposed above.
Housing density	29	35	Support PPO HOU9 and Question 29, subject to the following amendment - Insert at end: “…provided that all parking needs should be met on site”..
Conversion of dwellings	30	36	Support.
Development involving residential gardens	31	37	Support
Extensions and outbuildings within a residential curtilage	32	38	Object to Bullet Point G of PPO HOU12. A  proviso should be added to prevent outbuildings in  advance of front building lines. Support Question 32, subject to the insertion of the proviso above.
Residential amenity	33	39	Object to Bullet Point G. Remove “unacceptable”.  Nuisance, pollution and contamination are by definition unacceptable. Support Question 33, subject to the correction above.
8. Economy Economic development	34	40	Comment on paras. 8.0.3 to 8.0.5.  More than 26 ha. will be lost to employment uses in this plan, much of which is currently in use by Small and Medium-sized Enterprises, which are important for their function in servicing the local economy.  We do not consider the Council is best placed to be the judge of whether one type of employment activity is better than another.  The needs of the whole spectrum need to be addressed. Object to PPO EC1.  This aspiration is undermined by other policies in the plan.  See above.
Defined employment sites	35	41	Object to the inclusion of Lower Mount Farm in Table 8.  This site only has the benefit of a temporary planning permission.  It is a non-conforming use within the Green Belt and permanent planning permission should not be granted. Object to Question 35, consequential on comments above.
Other sites and loss of employment uses	36	42	Object to PPO EC3.  This PPO is inconsistent with the removal of 26 ha. from employment uses to residential. Object to Question 36, consequential on comments above.
9. Town Centres and Retail Maidenhead and Windsor Town Centres	38	43	Object to PPO RET2: What does the Borough mean by ‘a high proportion’?  A lack of definition is unhelpful.
10.  Tourism Tourism development	42	44	Support PPO TM1, subject to the following comment: Much of the Thames lies within the Green Belt/countryside.  Any tourist-related development should be subject to the strict controls on development for these areas promoted in other parts of the plan. Support Question 42, subject to PPO TM1 being improved to acknowledge the concerns expressed above.
Visitor accommodation	43	45	Object to PPO TM2.  Paragraph 2 of the PPO needs to be modified to ensure the siting of campsites and holiday parks is not detrimental to the countryside. Object to Question 43.  The PPO does not allow for the protection of the countryside.
11. Historic environment	44	46	Object to PPO HE1.  The policy proposes the continuation of the present reactive approach.  A proper Local Heritage Asset Register should be commissioned. Object to Question 44 consequential on above.
Archaeology	47	47	Object to PPO HE4.  The policy proposes the continuation of the present re-active approach.  A proper Local Heritage Asset Register should be commissioned Object to Question 47 consequential on above.
12. Natural resources Preferred areas for new waste facilities	55	48	Object to PPO NR5.  Hindhay Quarry should be removed from the list of sites where further development will be supported, since it is too close to existing residential properties. Object to Question 55 consequential on above.
Renewable energy generation	59	49	Object to PPO NR9 and Question 59. As written the PPO would give a blank cheque to any such development in the open countryside without any reference to the scale of develop-ment.  The bullet points in the PPO need to be beefed up significantly if this policy is to be made acceptable.
Managing flood risk and waterways	60	50	Support PPO NR10, subject to a requirement that any new development should be subject to an obligation to maintain any watercourse on or adjoining the site.
13. Environmental protection Air pollution	62	51	Object to PPO EP2 and Question 62.  The PPO is far too permissive. Since the PPO refers to AQMAs, no proposals should be supported which increase air pollution.
Artificial light	63	52	Support PPO EP3 and Question 63.
Contaminated land and/or water	65	53	Comment: This PPO (EP5) would imply that the proposed residential site west of Whyteladyes Lane, Cookham, which would be likely to affect an SPZ, should be deleted
14. Natural environment Open spaces	69	54	Comment: It is not possible to provide any meaningful input since the supporting material is not complete. But open spaces are important and the development of criteria for assessment (proposed, but not developed) should be a priority.
15. Infrastructure Sustainable transport	73	55	Comment: In the light of (a) the arrival of Crossrail, and (b) the revival of Maidenhead Town Centre, the Local Plan needs to spell out how access and parking are going to be provided to cater for these developments.  It is not sufficient to leave these important matters to the Local Transport Plan, which does not cover them adequately. OBJECT to Question 73, consequential on the above.
Developer contributions	74	56	Support.
Water supply and sewerage infrastructure	76	57	Support and comment: Since much of the existing water and sewerage infrastructure is ageing, we would expect strong requirements for improved facilities for new developments.