bracknell forest borough council ldf

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.


2

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”.


4

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”.


6

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.


8

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,


10

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

[email protected]

bracknell forest borough council ldf

Documents