Borough Local Plan
The Borough Local Plan is a statutory document which will form the basis of planning and development decisions for the period up to 2033 and, when it is finally adopted, will replace the current local plan which is out-of-date. It has had a long gestation period. The first draft came out in 2014 and the latest version: Borough Local Plan 2013-2033 incorporating Proposed Changes, appeared in October 2019.
Our principal concern has been the extent of new housing development proposed in Cookham, which will amount to some 270 new homes on 3 sites. Our contention is that the plan has failed to take account of the impact of this development on village services and on local roads, in particular The Pound and Cookham bridge. Our representations at the EIP also included: changes to Green Belt policy, which we consider would have a negative impact on Cookham Dean; agricultural development; the Royal Borough’s proposed policy on tall buildings; and the designation of the Poundfield as a Local Green Space.
Update February 2022
All the representations have now been considered by the EIP (Examination in Public) inspector, who has now advised the Royal Borough that she considers the plan is ‘sound’ and should proceed to adoption. Her recommendations are expected to be adopted at an Extraordinary meeting on the 8th February.
Her report is available on RBWM's website for anyone who wishes to view it. It's a lengthy document and we thought that these notes prepared by our chairman Bill Perry for The Parish Council make a shorter yet very interesting read for those concerned about what the new BLP means to Cookham.
Note to Parish Council regarding Borough Local Plan.
From Cookham’s perspective, two of the most important aspects are that the Inspector’s Report dismisses all the representations made against development sites AL37 (Lower Mount Farm) and AL38 (Strande) and their consequent release from the green belt.
The Inspector concludes generally that the BLP is soundly based insofar as it calculates housing need. She adds both that it is right to concentrate housing development in urban areas so far as is possible, as it does, and that there are limits to that strategy which means that some green belt must be released for housing.
The Inspector says in paragraph 99 that: “the Council has sought to maximise the use of previously developed land by pursuing an urban spatial strategy. The Housing & Economic Land Availability Assessment 2019 (HELAA) demonstrates how it was proactive in its efforts to identify potential development sites (PC-011, paragraph 2.6) and, as explained above [her Issue 2], it has taken an appropriate approach to calculating site densities. Consequently, it is very unlikely that the capacity of brownfield land has been underestimated to the extent that Green Belt release would be unnecessary.”. Thus she concludes that since the housing calculations are sound, exceptional circumstances exist justifying the release of green belt.
She also concludes that the green belt sites which have been released are appropriate. This analysis is to be found in particular under Issue 10, her pages 54 – 58. Paragraphs 226 - 228 on page 55 relate to site AL37 (Lower Mount Farm) and para 229 & 230 on pages 55 & 56 relate to AL38 (Strande Lane). In both cases she considers that the release of these sites from the greenbelt is justified.
On AL37 she says: “Site AL37 is at the southern end of Cookham Rise, surrounded by development including housing, a road with bus stops and some pavements, a water treatment works and an industrial estate. It adjoins agricultural land to the west, but the boundary here follows that of the built-up area to the north and south and is defined by trees and other vegetation. Thus the site is well-contained and, in this context, it is reasonable to expect that a development compatible with the character of the surrounding area could be provided. … the extent to which it is contained will mitigate against its loss to a significant extent and, because the site boundaries are well defined and durable, the threat of incremental spread is minimal.” (paras 227 and 228 respectively).
On AL 38, she says: “The site is well-contained with clearly defined boundaries and, from a Green Belt perspective, the Edge of Settlement Study finds it to be well related to the built-up area with an urban fringe character … . Overall, it makes a limited contribution to the purposes of the designation” (para. 229). She says of the flooding risk that: “It is … likely that the Exception Test can be passed at the planning application stage, although this requirement should be specified in the proforma to ensure effectiveness” (para. 230).
The Inspector dismisses the traffic objections to the Cookham sites, even taking the Wycombe and other sites into account. She says in that latter respect in para. 24 that: “Overall, in relation to the matters … referenced in the Duty to Cooperate Compliance Statement and the NPPF, the Council has engaged constructively, actively and on an on-going basis in the preparation of the Plan. I therefore conclude that the duty to cooperate has been met.”
Specifically on Cookham traffic she says in para 107 that: “At the more localised level the modelling does highlight some potentially material issues, such as the worsening by 13 seconds of an existing 102 second delay northbound across Cookham Bridge in the morning peak [which means she does not accept Paul Strzelecki’s modelling]. However, the balance of the evidence suggests that this situation is not unusual at such “pinch-points” in the road network, and that it would not have a wider knock-on effect for the network as a whole. Therefore, while undeniably frustrating for both residents and commuters in the area, the additional impact of development could not be described as “severe” [which is the test for refusing development on highways grounds]”.
It may be worth mentioning that regarding the ‘Maidenhead Golf Course’ site (AL13) she analyses the issues in paras 153 – 161 and concludes that: “Overall, the effect of removing this site from the Green Belt would be limited, notwithstanding its large size” (para 159) and that: “Set against the limited harm to the Green Belt, the analysis above demonstrates that the site would make a substantial contribution to delivering the Borough’s housing needs in a location consistent with the spatial strategy without reducing public access to open space or significantly eroding the character of the locality. It would provide other supporting infrastructure likely to be of wider benefit and, of course, development here would itself benefit from the full range of services and facilities available in Maidenhead. On balance, therefore, AL13 is a suitable site for release from the Green Belt and there are exceptional circumstances to justify it.”
On other subjects, we objected to Lower Mount Farm’s designation as an Established Employment Site. The Inspector considers (para. 90) that: “The designation of Lower Mount Farm Cookham as an Established Employment Site in the Green Belt is justified on account of the uses present, but modifications are required to explain the provisions which apply to these types of sites and to give confidence that Green Belt policy will continue to apply. MM22 includes the necessary additions …”.
In her paras. 131 – 133 the Inspector approves the new policy on tall buildings. (We sought amendments.) She considers that it “represents a necessary response to an issue with the potential to significantly affect [sic] the character of the Borough”. She does, which may be helpful, add that: “In summary, the policy is intended to convey that tall buildings should be exceptional; defined and height-limited relative to the existing “context height” in any given place; confined to urban settings and sites where they can aid intensification and/or mark somewhere important in an area; and be acceptable in respect of the usual factors including townscape, landscape, heritage and amenity etc.” She then mentions that: “The Council intends to prepare an SPD [Supplementary Planning Document] …” which suggest that we may have further work to do here.
Paragraphs 285 – 287 of the Report deal with Poundfield. On this, fortunately, after analysis (and on the basis of MM 47) the Inspector concludes that: “Poundfield [she accepts the whole site] meets the criteria in paragraph 77 of the NPPF and so its designation as a LGS [Local Green Space] is justified. It does not matter that it has not been previously incorporated into the Green Belt because the latter is a different designation required to fulfill different purposes.”
Chairman, The Cookham Society