campaign for fairer housing

  WBC’s Local Plan has run into a massive headwind of opposition from influential official bodies and other associations. Their responses to the Reg 19 consultation make it clear how much the Council would have to do before the Plan could be considered sound. This news item summarises the main objections found in their submissions.

Waste water treatment upgrade needed - Environment Agency
The Environment Agency expresses some concerns about flooding and mitigation of the flood risk posed by the proposed Hall Farm development. Its major concern, though, is that waste water treatment infrastructure in the Borough would be unable to cope with the greatly increased population envisaged. The Environment Agency states that it will not approve any large-scale planning applications until significant upgrades are in place at Arborfield and Wargrave Sewage Treatment Works.
    
Ashridge wants to be added
The Ashridge Consortium’s submission, prepared by the consultants Boyer, offers a powerful critique of the WBC local plan at several levels. 
    It dismisses the often-heard criticism of the Ashridge plan that not all of the landowners there are signed up to the Consortium’s development proposal, whereas the Hall Farm land owners are all on board with the ‘Loddon Valley Garden Village’ plan. It says on the contrary that the Ashridge landowners are all signed up to their consortium, while the Hall Farm landowners have yet to get to that stage.
    Other points made by the submission are:- WBC fails to meet the requirement to cooperate with neighbouring councils, by not allowing for Reading Borough Council’s unmet housing need; furthermore, the Plan’s commencement date has been incorrectly calculated as 2023/24, whereas the Standard Method for calculating housing need uses 2024/25 figures. Planning regulations apparently require the two time-points to  be the same.

The houses won't be built in time.
The Boyer submission’s most telling points are directed at the feasibility of building a SDL at Hall Farm. It shows in detail why the timescale for delivery of new housing is far too optimistic, bearing in mind the large amount of initial infrastructure provision that would be required before any houses could be built. (Not to mention the time required by statute to survey the entire Hall Farm site for gravel and remove it.) The process of the Inspectors’ examination of the Local Plan alone is likely to last a year, before anything else can happen, but WBC does not acknowledge as much. 
    What all this means, the Ashridge consortium says, is that the Hall Farm plan is critically exposed to lengthy delays that would endanger the Borough Council’s housing supply requirement. 
    There is a far less attractive part of their submission. Boyer does not say that the Hall Farm development plan should be taken out and replaced by development at Ashridge. It argues for adding Ashridge to the Local Plan. From our point of view, that would be a very unwelcome outcome. At least, however, the Ashridge consortium’s incisive arguments should make it clear to Inspectors that approving the so-called London Valley Garden village proposal would be the wrong decision.

Parish councils say no    
Unrealistic infrastructure costs - Arborfield & Newland P.C.
The two parish councils most directly affected by the Hall Farm scheme are strongly opposed to it. Arborfield Council has submitted a well-argued report by consultants Bell Cornwell, which makes a number of excellent objections.
    Especially as regards Hall Farm, it calls the Local Plan unrealistic in terms of infrastructure costs - which are moreover not fully considered by the externally conducted ‘viability study’! It also calls out the ‘minimal detail’ provided by WBC on timing of infrastructure delivery. The submission notes that the traffic model is clearly out of date. 
    In addition, Arborfield Parish Council draw attention to WBC’s bad track record on ensuring infrastructure provision to the previous SDLs, resulting in an 8-to-9 year lag before it materialises. This points to the risk, they say, that the developers would fail to provide infrastructure in timely fashion, not least with the M4 Bridge. If the latter were to be significantly delayed, perhaps beyond the plan period, there would be very serious consequences for traffic flows until that time. 
    As regards the flood risk, Bell Cornwell’s submission observes that developers are required only to ‘consider and take the opportunity as appropriate’ to provide offsite flood mitigation. They are not explicitly required to implement them. So areas upstream and downstream of the Hall Farm site could suffer flooding as a result of water run-off from all the new housing, without the developers being obliged to mitigate against this possibility.
    
Doesn’t respect NPPF - Shinfield P.C.
Shinfield Parish Council's submission finds the LPU violates the 2023 National Planning Policy Framework (NPPF), in various respects:- By ignoring more sustainable sites, it doesn't achieve sustainable development; it doesn't ‘promote healthy and safe communities’; it doesn't promote sustainable transport; it doesn't ‘meet the challenge of climate change and flooding’. In particular, the Parish Council notes that Shinfield's communities are not offered ‘a choice of secondary schools’ as would be required by the NPPF. In addition, the focus on development at Hall Farm places housing far from active travel infrastructure. The LPU does not ‘make as much use as possible of brownfield land’, as required by the NPPF. Development at Hall farm would significantly increase flood risk from water run-off. 
    The Shinfield Parish Council submission is very effectively presented: it directly compares the LPU with quoted NPPF requirements, and shows how it is in clear contradiction with them.
    

‘Active travel’ not well addressed - Reading Borough Council
Reading Borough Council’s submission says it ‘cannot support the plans for Loddon Valley Garden Village as it [sic] stands’. It goes on:
    ‘RBC’s main concerns relate to transport. In particular we have not been provided with information to clearly demonstrate that a development on this scale can and will be highly accessible by public transport, walking and cycling to services, facilities and the rest of the transport network, including links into central Reading. We do not agree that active travel and public transport have been adequately addressed within the Proposed Submission Plan with regard to Loddon Valley Garden Village.
    The proposal of a new bridge ending at Lower Earley Way that is open to all traffic will encourage bus travel, but will certainly also encourage car travel to Reading via Lower Early [sic] using congested and unsuitable roads. Bus routes in Lower Earley are already experiencing considerable delays and increasing traffic in this area will make bus journeys longer, less attractive and less reliable.’
    RBC exposes the Wokingham Council ‘active travel’ narrative for the hollow sham that it is. For all the pious statements about encouraging cycling, public transport, and walking, the Hall Farm development would be a massive generator of extra vehicle traffic.  RBC should know the true position - Wokingham Borough is critically dependent for public transport on Reading Buses. When Reading says its bus services would be badly affected by the Hall Farm plan, we’d better believe it.
    NB: The Ashridge consortium claims that Reading will have an unmet housing quota in the coming plan period (see above), but RBC says it will not:
    ‘RBC does not consider that there is a need to make any additional allowance for unmet need from Reading in the Wokingham Local Plan Update. The most up-to-date position is that RBC expects to deliver enough homes over the remainder of its adopted plan period (to 2036) to more than meet its own adopted housing provision plus any unmet need within its own boundaries.’

     The above is an inevitably selective summary of the many compelling objections raised by these and other official bodies and associations. Visitors to this site are encouraged to go to https://www.wokingham.gov.uk/planning-policy/emerging-local-plan-update/proposed-submission-regulation-19-consultation-responses, to read them in detail for themselves.
     Altogether, they give the impression that the LPU cannot rationally be considered ‘sound’ by the Planning Inspectorate. 
    However, WBC has responded to these objections and in a future news item I will summarise how it seeks to deal with them.