Winkfield
Neighbourhood Plan Pre-Submission Consultation Response Schedule
(April 2022)
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Policy/ Para.
Number
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Comment Type
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Comment
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Comments on the
Pre-Submission Winkfield Neighbourhood Plan (2022)
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General comment
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The Pre-Submission Bracknell Forest Local Plan (BFLP)
plan period is 2020-2037. You may wish to revise the
Winkfield Neighbourhood Plan period (2021-2037) to cover the same
period.
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General comment
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Where there are
overlapping policy designations such as with Local Green Spaces and
Local Gaps there is a need to ensure there is no conflict between
the policies.
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General comment
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Need to ensure consistency with the use of the
terms ‘supply’ and ‘need’ with regards to
housing.
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Para 1.10
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Clarification
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Para refers to the Bracknell Forest
Council’s Strategic Environmental
Assessment (SEA) Screening Opinion dated August 2016, which
concluded that there was a requirement for an SEA given the content
of the plan. At the time, the plan intended to allocate sites
for development. The Screening Opinion notes that it is a
‘snapshot in time’. The plan has since evolved,
whilst the Neighbourhood Plan was not able to identify suitable
sites to allocate, it supports development outside of the
settlement boundary, including in the Green Belt, in certain
circumstances, going beyond the support provided for such
development by other applicable policies. As such the outcome
of the Screening Opinion is considered to remain valid, therefore
an SEA is still required.
(Comments on the SEA of the Winkfield
Neighbourhood Plan (2020) are available below this table.)
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Para 1.13
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Clarification
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Since 2016 when the last SEA / HRA Screening
was undertaken by the Council, the following should be noted:
·
In April 2018, in the case People Over Wind & Sweetman v
Coillte Teoranta (“People over Wind”), the Court of
Justice of the European Union clarified that it is not appropriate
to take account of mitigation measures when screening plans and
projects for their effects on European protected habitats under the
Habitats Directive. In practice this means if a likely significant
effect is identified at the screening stage of a habitats
assessment, an ‘Appropriate Assessment’ must be
undertaken.
·
A new basic condition came into force on 28 December 2018 to allow
neighbourhood plans and orders in areas where there could be a
likely significant effect on a protected habitat to undertake a
full ‘appropriate assessment’ to demonstrate how
impacts will be mitigated, in the same way as would happen for a
Local Plan.
The Council has discussed the need for a HRA
with Natural England who have confirmed that a full Appropriate
Assessment of this Neighbourhood Plan is required.
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Para. 2.34
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Amendment
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Since leaving the European Union, Special
Protection Areas and Special Areas of Conservation in the UK are no
longer part of the Natura 2000 network of sites. These now
form part of the national site network. Amend as follows:
“…these areas are called Nature 2000
sites part of the national site
network and are internationally important for threatened
habitats and species.”
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Para 2.35
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Amendment
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References in to flooding are welcomed.
Clarification is recommended for the sentence “Nearly the
entire Parish is considered a ‘Nitrate Vulnerable Zone’
for surface water flooding.” Nitrate Vulnerable Zones
are areas designated as being at risk from agricultural nitrate
pollution and whilst surface water flooding of farmland may cause
increased nitrate run-off, surface water flood risk is a separate
issue and one that is important in the parish. This is
repeated within the glossary and abbreviations section of the plan
which also need amending.
Flood risk from fluvial, surface water and
groundwater sources are an important consideration in the Parish.
However, it is recommended that references to flood risk are
extended to include groundwater emergence. Further
information regarding the flood risk from all sources of flooding
within the Borough can be found in Bracknell Forest Strategic Flood
Risk Assessment (SFRA).
This recommendation is in line with the July 2021 amendments to the
National Planning Policy Framework (NPPF) which require
consideration of the risk of flooding from ‘any
source’. Consideration of all sources is relevant in
the parish, there are areas of the parish where groundwater levels
are either at or very near (within 0.025m) to the ground surface,
in some areas this coincides with surface water flood risk.
The need to consider all sources of flooding was previously
identified within the Council’s SEA Scoping Opinion (November
2017).
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Para 4.24
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Information
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The Council has planned for highway
improvements on a strategic level over many years. This is
reflected in the Urban Traffic Management and Control programme
which has introduced MOVA control at major signals to enhance
capacity and thus ease traffic pressures. Plans for major
highway improvement works across the borough have come to fruition
every year, including those on the London Road corridor that pass
through the parish.
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Para 4.25
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Information
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With regards to the residents’ survey
which identified a need for junction improvements, the Council did
have a concept scheme for the introduction of signal control at
Braziers Lane. However, this would have resulted in a
departure from design standards due to the lack of available land
as there was no intervisibility, and vehicle manoeuvres would have
required stop-lines to be a considerable distance back from the
junction. At Maiden’s Green, the Council has a concept
roundabout design that is part of the Local Plan Transport Impact
Report produced in 2021.
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Objective F
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Amendment/clarification
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Objective F within the plan refers to ensuring
no significant effects on the Thames Basin Heaths Special
Protection Area (SPA). It is recommended this reference is
broadened to encompass the Windsor Forest and Great Park Special
Area of Conservation (SAC) which is also located within the Parish.
It could also be clarified to be clear that the objective
relates to no significant negative effects on these sites.
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Para 5.7
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Suggestion
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Consider including a
monitoring framework setting out details on what will be monitored
and indicators. Locality provide guidance which is
available here:
https://neighbourhoodplanning.org/toolkits-and-guidance/how-to-implement-monitor-and-review-your-made-neighbourhood-plan/
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Policy W1
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Suggestion
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The policy is a mix of
general approach and specific policies. Suggest the specific
policy elements (Green Belt villages and strategic gaps) are moved
into a new policy (Green Belt villages) and added to the existing
gaps policy (strategic gaps).
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Policy W1 criterion C 5
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Consistency
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The policy identifies a strategic gap between
Bracknell and North Ascot. This gap follows the same
boundaries as the Bracknell – North Ascot strategic gap in
the emerging BFLP. The emerging BFLP is currently at
examination and the boundary of the gap may change. This would need
to be reflected in the Neighbourhood Plan.
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Policy W1 C 3
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Clarification and consistency
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The list of Green Belt
villages does not include Cheapside which is identified in the
Pre-Submission BFLP as a Green Belt Village. It is noted
that Cheapside is identified as a Green Belt Village on the
Policies Map, therefore unsure why omitted.
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Policy W2
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Suggestion
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The policy could include some wording setting
out how proposals in locations adjacent to the character area
boundaries would be expected to follow the design principles of the
relevant character area.
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Policy W2
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Suggestion
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The policy does not give any details on how
‘high quality of design’ is measured in building terms,
as it focuses on reference to landscape in the Character Area
Assessments. Suggest that ‘high quality’ should
also include good quality materials which are sympathetic to the
local built heritage, appropriate storey heights, roof forms,
fenestration and architectural detailing.
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Policy W2
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Suggestion
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It would be helpful if the bullets under the
policy points were numbered to make it clearer which part of the
policy is being referred to when the plan is in use. Also
applies to Policy W4.
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Para 5.12
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Amendment
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Amend last sentence as follows:” Other
relevant policies include those set out in the Bracknell Forest
Borough Local Plan and emerging Local
Plan…”
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Para 6.4
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Clarification/ consistency
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Add the settlements listed in the para (North
Ascot, Chavey Down, Winkfield Row, Martins Heron & The Warren
and Forest Park) to the policy criterion C1 for consistency with
other parts of the policy.
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Para 6.5
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Clarification
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Should be clear that the Green Belt villages
boundaries are identified in the emerging Bracknell Forest
Development Plan for the purposes of infilling only.
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Policy W4 A
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Clarification
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Criterion A states: “On sites of less
than 10 dwellings, at least 80% of the
dwellings should be a mix of 1, 2 and 3-bedroom homes.”
Unclear where the 80% is derived from and what evidence
supports this as Table 8.1 in the supporting text states that 32%
should be 4+ bedrooms, not 20%. Further justification/evidence is needed to
support the 80%.
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Policy W4 A
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Suggestion
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Specify that the requirement for a mix of 1, 2
and 3 bedroomed homes does not apply to developments of specialist
housing for older persons such as housing with support or housing
with care.
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Policy W4 C
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Suggestion
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Would be useful to have some supporting text
that expands upon and explains criterion C.
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Policy W4 C 1st bullet
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Suggestion/ amendment
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Whilst starter homes feature in the Housing
and Planning Act 2016 and NPPF glossary, the funding and relevant
legislation required to implement them has never come into force
and so there is no likelihood that any starter homes will come
forward. Therefore, suggest deleting this requirement.
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Policy W4 C 2nd bullet
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Clarification
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Unsure how the requirement to encourage
“homes specifically developed for private rent” can be
controlled through the planning system.
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Policy W4 C 4th bullet
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Suggestion
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Sheltered and extra care normally require
quite large developments to achieve economies of scale and be
viable (e.g. minimum 60 units for an extra care home), therefore
they may not be appropriate in Winkfield. Could consider
encouraging other forms of accommodation for elderly people if
there is a need such as bungalows.
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Policy W4
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Suggestion
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It would be helpful if the bullets under the
policy points were numbered to make it clearer which part of the
policy is being referred to when the plan is in use.
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Policies W5, W6 and W7
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Clarification/ amendment
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Policies W5, W6 and W7 provide in-principle
support to development. Whilst it is understood that the plan
should be read as a whole, and with consideration of other policy
requirements (such as the NPPF and Bracknell Forest Development
Plan), supporting text is needed to note how the in-principle
support of development provided by the Winkfield Neighbourhood Plan
relates to wider considerations/constraints (such as flood risk,
biodiversity, landscape, heritage).
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Policy W5
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Suggestion
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Where there is a difference to national policy
on rural exception sites this should be made clear in the policy
and supporting text.
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Policy W5 A
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Amendment/ clarification
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The rural exceptions
policy requirement for the site to be adjacent to a settlement
boundary is not a requirement of the NPPF. This needs to be
justified in the context of Winkfield.
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Policy W5 A
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Amendment
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Amend to clarify that the developer needs to
undertake the local needs survey.
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Policy W5 D i
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Amendment
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Amend to add a requirement that the financial
appraisal demonstrating the viability of the scheme is
independently assessed and that the assessment will be paid for by
the developer.
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Policy W5 D iii
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Clarification
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It is not clear what this criterion is seeking
to achieve, as it is not clear how meeting local needs relates to
design and visual character. This could be a basic condition matter
as the plan may not be considered to meet the NPPF requirement that
‘plans should contain policies that are clearly written and
unambiguous, so it is evident how a decision maker should react to
development proposals’ (para. 16(d)).
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Policy W5 E ii
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Suggestion
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The requirement regarding site size should be
amended as follows “sites should not
cumulatively be larger than one hectare in size or
exceed 5% of the area of the existing settlement within its
boundaries”.
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Policy W5 supporting text
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Suggestion
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Exception sites are justified where they very
clearly meet local needs (or borough needs in the case of
entry-level sites). It would be useful if the supporting text
could set out what local needs the Neighbourhood Plan is trying to
meet, what types of affordable housing are most needed to meet
local need and might therefore justify development on exception
sites, plus how cumulative development on Green Belt sites will be
avoided.
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Policy W7
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Suggestion
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This policy may not necessarily prevent the
loss of economic floorspace, since i, ii, iii are in the context of
A which is for employment/ retail proposals, so it does not address
loss of economic uses to residential, for example.
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Policy W7
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Clarification
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It would be helpful if the Neighbourhood Plan
included a definition of what ‘employment’ is (see
emerging Bracknell Forest Local Plan which defines employment uses
as BIDS uses). Similarly, ‘small-scale’ for both
employment and retail should be defined. In the emerging BFLP
smaller business units are 500 sqm or less.
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Policy W7 and para. 10.1
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Amendment
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The final sentence of Para 10.1 states that
‘these uses’ should be located within or adjacent to
existing settlement boundaries, noting restrictions on development
outside Green Belt villages. Whilst NPPF paras. 84 and 85
relate to a prosperous rural economy, the Neighbourhood Plan reads
as if it is supportive of development in the Green Belt and
countryside. Retail uses are also subject to a sequential
test where town centre uses (such as retail) should be located in
town centres, then edge of centre and out of centre should only be
considered if no other sites are available. Suggest policy is
amended to read “will be supported in appropriate
locations within or on the edge of settlements
provided they…” and supporting text updated to
say this may include adjacent to existing settlement boundaries
where suitable opportunities exist.
This is not in general
conformity with strategic policies in the Development Plan or
consistent with national policy and therefore does not meet the
basic conditions.
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Para. 10.1
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Clarification/ suggestion
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Such proposals will be subject to other
considerations and policies and associated tests, such as the
sequential test. For clarity, Green Belt villages are not
defined as ‘settlements’ in the emerging BFLP, they
have simply been defined for the purposes of infilling, alone.
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Policy W8
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Suggestion
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First 2 paragraphs should be numbered and
could be moved to the supporting text beneath the policy.
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Policy W8 2nd para
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Amendment/clarification
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First sentence states that:
“Biodiversity net gain is mandated for developments requiring
planning permission”. However, biodiversity net gain is
not yet mandated. Secondary legislation following on from the
Environment Act will make it mandatory in 2023. Text should
be amended to reflect this.
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Policy W8 A
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Amendment
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Policy should be clear about what counts as a
net gain and include percentage figure otherwise proposals may
claim a very small net gain e.g. 0.01%.
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Policy W8 B
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Amendment
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Amend policy to delete “in
particular” at the start of the sentence as the wording is
not considered necessary.
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Policy W8 C
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Amendment
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First sentence should be amended to refer to
ecological rather than habitat. The second sentence should
refer to native species, rather than trees, shrubs and grasses so
covers all plant forms as follows: “As part of its
requirements to demonstrate biodiversity net gain, development
should be designed to retain trees, shrubs and hedgerows of
arboricultural, habitat ecological and
amenity value on-site and to conserve and enhance connectivity to
the wider green and blue infrastructure networks. Where this is
accompanied by new planting, this should consist of native species
of trees, shrubs and grasses acting as stepping
stones for wildlife.
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Policy W10
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Clarification
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Suggest amending reference to light to
‘artificial light’ for clarity.
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Figure 11.1
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Suggestion
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The Council is currently looking at Green
Infrastructure (GI) corridors as part of the GI Strategy to support
the emerging BFLP. The corridor in Fig11.1 overlaps partially
with one of the biodiversity corridors that have been identified.
We can share information on GI corridors to help integrate
the corridors.
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Para 11.4 3rd bullet
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Suggestion
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The policy mentions the use of native species
so it may be worth explaining that native species provide
foodplants and habitats for a greater range of species than
non-natives.
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Policy W10
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Suggestion
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Is there any evidence of particular areas in
the parish where dark skies should be protected? Perhaps
linked to the character areas assessments? Whilst the
glossary states these will be defined and shown on the policies
map, they are not currently there. These should be spatially
defined on the policies map and the policy amended to specifically
protect these areas. Whilst advocating low energy lighting is
applicable to all the parish, it is not specifically related to
protecting existing dark skies per se, i.e. it would make minimal
difference to a development proposal in an already urban area.
It would be more helpful if there was a defined area(s) for
the policy to apply to.
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Policy W11 and para
11.16
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Amendment to evidence
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There is no evidence document setting out how
the Local Green Spaces were assessed as being suitable against the
criteria set out in the National Planning Policy Framework paras
101 and 102. This should be provided.
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Para 12.2 1st bullet
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Clarification
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Suggests that the newly reconstructed
junctions at A329 junctions with New Forest Ride (Mercedes Garage),
Priory Road (The Royal Foresters pub) and Fernbank Road (LVS
School) are the problem, as it doesn’t acknowledge that they
were built to alleviate a greater congestion problem and have
reduced the queues and delays along this corridor.
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Policy 12.4
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Amendment/Clarification
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With regards to safer pedestrian and cycle
paths around schools, this infrastructure is something the Council
has addressed previously so it would be helpful if the text could
be amended to clarify which particular schools or routes need
further attention.
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Policy W13
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Clarification
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The policy seeks to
encourage access to and from Martins Heron station for pedestrians
and cyclists. However, one of the proposed measures to
achieve this includes “b. the provision of additional car
parking spaces” which may be contrary to the aim of the
policy.
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Para 13.4.6
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Clarification
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With regards to the list of potential
infrastructure projects for traffic calming some of these routes
(Forest Road, London Road, Bagshot Road, Swinley Road and New
Forest Ride) are major strategic roads which would not lend
themselves to traffic calming schemes as initiatives would push
traffic onto less appropriate routes.
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Para 13.4
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Amendment
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Amend text to add in hyperlinks to the
evidence documents listed.
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Policies Map Inset 2
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Amendment/Clarification
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Unclear where the settlement boundary is to
the east of Bullbrook - the settlement boundary may need to be
brought to the top of the layers to make it clearer. Also
there is a dashed line to the west and north of Heathfield School
which is not on the legend and may need to be deleted. See
yellow highlights on the extract below:
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Glossary – Evidence Base
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Amendment
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The definition for ‘Evidence Base’
need amending to state that the evidence base is comprised of
reports and technical analysis which have helped to shape the
plan.
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Appendix B – Schedule of evidence
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Amendment
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Does not list the Strategic Environmental
Assessment (SEA) of the Winkfield Neighbourhood Plan Environmental
Report (February 2020). Amend to include reference to the
relevant SEA.
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