LETTER REGARDING SANDLEFORD AND 2ND PLANNING APPLICATION

This letter contains objections to the Warren Road access and is very thorough in its objections to other areas of the Sandleford plan. If you would like to add your name and address to the Supporters list that will accompany this letter to West Berkshire Council please email peter@saynotosandleford.org.uk. Apologies for the awkward way this is displayed but I cannot attach a file so this is the next best thing. It can also be viewed on the "Andover Road and surrounding area - Residents Association Facebook" page: To: planapps@westberks.gov.uk Mr Jake Brown West Berkshire’s Local Planning Authority Council Offices Market Street Newbury RG14 5LD 29th January 2016 Ref: 15/02300/OUTMAJ - Sandleford Park & 16/00106/OUTMAJ - Sandleford Park Dear Mr Brown SayNoToSandleford “snts” is a campaign group initially formed to oppose the selection of Sandleford Park as a strategic site to create an urban extension to Newbury of some 2,000 homes in a mixed use development. Subsequent to the site being adopted by West Berkshire Council we have subsequently worked to ensure that the development of 2,000 homes works not just internally but also with the surrounding community. We have 261 subscribers to our newsletters about the development and well over 100 people attended our public meeting on the 19th January 2016 to discuss the application and the proposals being made by the landowners and developers of the site. 116 people are signatories to this letter. BACKGROUND When we put up our case to the Planning Inspector in the 2012 hearings our concerns as to why Sandleford was the wrong choice concentrated on four areas: 1] Scale: 2,000 homes would dwarf the surrounding area causing a loss of identity and overwhelming local services; 2] Location: so many homes on one side of the town, alongside the nearby Racecourse development, would put a strain on infrastructure that would be hard to mitigate, alongside the fact that the site was a fair distant from the town centre that made green alternatives to the use of the car hard to achieve; 3] Design: that creating an estate with just two all vehicular accesses to Monks Lane would create a giant cul de sac and we noted a March 2010 master planning meeting where a proposed access from the A339 had been deliberately taken off the table as it would question the deliverability of the site; and 4] Ecological: it was hard to understand how a development of this scale could be anything other than harmful to an area that contained a number of important ancient woodlands and ecologically bio diverse areas that provided important links to nearby SSSIs. snts response to planning application 15/02300/OUTMAJ & 16/00106/OUTMAJ! 1 of 20 Taken together we questioned how building a mixed use development of 2,000 homes in this particular location could in anyway be described as sustainable. Clearly our arguments did not hold sufficient sway with the Planning Inspector to warrant him overturning the Council’s choice and he approved the Core Strategy which included Sandleford in May 2012. Subsequent to that decision a meeting was convened by West Berkshire Council and representatives of the Sandleford Partnership with various stakeholders in the process, including our campaign group, where it was emphasised that the upholding of the Core Strategy was only the start of the process, and that they were keen that irrespective of where each party stood on the merits or otherwise of the site selection that we should now work together to help shape Sandleford so that it would be the best it possibly could be not just within itself but also with the wider community. We were told that they wanted to positively engage with us on the process moving forward. This promise was warmly welcomed by everyone who attended that meeting. This mantra of engagement has been carried forward by Bloor Homes in their Design & Access Statement (Sept 2015) where on P36 in a table showing their engagement with key stakeholders and two public consultation meetings alongside public meetings with Newbury Town Council and Greenham Parish Council they state: “Bloor Homes and representatives from Donnington New Homes, Newbury Town Council and Greenham Parish Council are in the process of setting up a Working Group. The group will have regular meetings and will work collaboratively to improve the proposals and ensure that consultation continues beyond the submission of a planning application” We know that this Sandleford Park Working Group has yet to meet. In spite of repeated requests to meet with local residents groups to discuss their concerns they have all been turned down including the opportunity to attend and present at our public meeting on the 19th January 2016. The public consultation events turned out to be tokenistic at best, at worse nothing more than PR exercises, where pre-formulated plans were presented to the general public. When challenged at the Newbury Town Council what had changed as a result of these events the answer was the additional access roads and the location of the primary schools - both these were initiated by West Berkshire Council as opposed to the general public. This lack of engagement would be worrying enough if it only involved ourselves and the more recently formed Wash Common Action Group: made up of concerned parents at Falkland Primary School and other residents directly affected by proposed changes to Warren Road. However it would appear to extend to some key parties within West Berkshire Council where Bloor Homes chose not to engage in a pre-application process with Highways and Transport. This shows an arrogance of approach by Bloor Homes that rarely results in good decision making. It reinforces the view that this development is being planted on Sandleford with little regard to the surrounding area. Moreover this lack of engagement puts to question discussions that are assumed to have been taking place with other interested parties: Park House School, is the land allocation suggested sufficient for their needs; Falkland Surgery, is sufficient capital being laid aside to enable them not only to expand their premises but also provide sufficient parking; there is a presumption that the site will have pedestrian access across the Rugby Club, what if any discussions snts response to planning application 15/02300/OUTMAJ & 16/00106/OUTMAJ! 2 of 20 have they had with the Club about this and without this what assumptions have been made on traffic movements for access to the Surgery and the new David Lloyd centre? The process is important as the lack of true engagement with various interested parties have led to plans being presented which in our view are incomplete and in need of much improvement. It is likely therefore that substantial re-working of the plans are going to be required before they are in a fit state to be approved which will inevitably cause further delays to the start of the project. We are aware that the Council is facing increasing challenges to its five year housing supply plans of which Sandleford is an important component and any delay to this programme increases the chances of planning appeals by other large schemes being successful. We have some suggestions therefore that we hope will be viewed constructively that will enable the Council to buy time whilst an acceptable scheme for Sandleford is worked up. It is hoped that going forward Bloor Homes will take note and properly engage with community groups, interested third parties as well as the various stakeholders within the Council’s departments to work up a proposal that has broad support across the spectrum of interests. INTRODUCTION While we will be looking at any proposal for this site with a view to how successful they are in overcoming our objections highlighted above, we are cognizant that from a planning point of view this application will be judged on how well it meets the Core Strategy and the guidelines laid out in the SPD (March 2015). With this in mind our view is this planning application is incomplete in that much of the traffic infrastructure is based on survey information that is out of date, and insufficient. By way of example Traffic Survey data for Andover Road and Monks Lane was taken before the opening of the Sainsbury Local and Garage on Andover Road, and the David Lloyd Centre on Monks Lane. The traffic survey data whilst looking at peak travel times fails to look at traffic flows and parking issues at school drop off and pick up times. There has been no survey work on pedestrian and cycle traffic particularly relevant when looking at the impact of pedestrian traffic on Monks Lane when Park House students leave the school. Moreover there has been no study of the impact of Saturday traffic on the northbound Sandleford link which regularly sees tail backs extending 10 or more cars on the A339, nor of the problems faced by shoppers leaving Tesco car park at peak times where queues of up to 40 minutes are regularly reported. Without this detail it is impossible to have any confidence in any of the traffic mitigation measures or to fully understand the impact of traffic leaving any of the proposed access points. This point has been very well made in both the Highways and Transport responses to the proposals. In addition we believe that the assumptions on the volume of traffic and its distribution coming to and from Sandleford is flawed, based as it is on early survey work of traffic distribution from nearby St John’s Ward and Falkland Ward both of which have large residential districts that are closer to the town centre and down the hill from Sandleford. It is likely therefore any model derived from these traffic patterns is likely to underestimate the number of car journeys emanating from and to Sandleford as well as their direction of travel. snts response to planning application 15/02300/OUTMAJ & 16/00106/OUTMAJ! 3 of 20 There is also no study on the impact of phasing of the project on traffic distribution loads, this is particularly evident before the northern parcels are linked to the western and central parcels (assuming the latter is started in tandem with the northern parcels) where all northern traffic will exit via Monks Lane and the A339 and the western parcels via Warren Road if approved. These will put particular strains on the infrastructure of the area which simply has not been considered. Moreover we understand that the four access points to the Sandleford development are still being worked upon and are incomplete even to the level where it is to be determined whether the accesses to and from Monks Lane should be T-Junctions or roundabouts, and where the access should be from the A339 where the Highway Officer supports our contention that the A339 should incorporate access to the Household Waste and Recycling Centre (HWRC). These are not reserve matters but fundamental to how the scheme works and its impact on its surrounding areas. It is impossible for the application to be judged let alone approved until these matters are resolved. As such our response is an interim statement to help formulate the proposals as we move forward, and snts reserves the right to amend its position as the plans evolve and anticipates that there will be a further round of consultation for the amended plans to be considered. Our comments pertain to both planning applications made by Bloor Homes regarding Sandleford Park, however the following section is specific to the separate application made with regards to Parcel N1: 16/00106/OUTMAJ - Sandleford Park 1) we are assuming that this application is the same as contained within Hybrid Application 15/02300/OUTMAJ but if not the applicant should be asked to provide a schedule of variation, to help navigate through the changes; 2) can the timetable for submissions to this application be made clear as we have yet to see orange notices in this regard but letters to households states the 19th February 2016; and 3) we would anticipate that responses to 15/02300/OUTMAJ will be carried over to this application as they pertain to the development of Parcel N1, this includes all concerns expressed about transport assessment whether from east or west of the site. We would like clarity as to whether this additional application was made at the request of/ or suggestion of a member of the West Berkshire Council or at the initiative of the developer. It should be noted that in the covering letter it still calls this application a hybrid application when we believe it is in fact a single application. We would add that putting in this separate application would appear to be contrary to the SPD (March 2015) which stipulates on P31 S1: snts response to planning application 15/02300/OUTMAJ & 16/00106/OUTMAJ! 4 of 20 S1. The Council requires proposals for the site to be brought forward by means of a single planning application for the site in order to achieve a comprehensive development and to ensure the timely provision of infrastructure, services, open space and other facilities in a properly coordinated fashion. As such by putting forward this separate application, regardless of justification, the developer is in clear breach of this condition of the SPD. If permitted it will allow Sandleford to be developed piecemeal without regard to the overall framework and infrastructure requirements of the complete site. As such it should be turned down and the application proceed under the original hybrid application 15/02300/OUTMAJ. With the above in mind our comments to the specific proposals in both applications are as follows: ACCESS [Warren Road/Andover Road Access ITB10083-GA-018 & 019] The proposed junction change to make Warren Road an all vehicular access point to the development is based on incorrect data. The 2012 Traffic Survey was done prior to the construction of the Local Sainsbury and Garage, and the Traffic Survey did not look at pedestrian or cycle movements especially at peak drop off and pick up times for the adjacent schools. In this regard we support the position papers put forward by Highways and Transport in their respective responses dated the 22/1/2016 The assumptions behind justification of Warren Road as an all vehicular access point look totally unrealistic and provide an unsound basis for deciding what all vehicular junctions are needed where. This is especially so on the assumption that all traffic leaving Warren Road will want to head south to access the Northbound A34, and so will relieve congestion at the Monks Lane and the Andover Road and Essex Road interchange. It is to be expected that a large proportion of traffic will want to head to the town centre and so increase traffic passing the schools and community facilities in the area and will directly impact drop off traffic for Falkland School with a right hand turn from that junction. While it is accepted that the current traffic issues in the area at school drop off and collection times are in themselves unacceptable and dangerous, interposing a busy interchange at this point seems an odd solution when just a pair of pedestrian lights would resolve much of the current issues. Moreover there seems to have been no consideration of the dangers of putting heavy construction traffic beside a route heavily used by school children and mothers with young children. This would seem to be a complete no-no from an Health & Safety perspective and in contravention of Highways guidelines for safe practice. Even restricting construction traffic to school holidays would not answer this problem due to activities put on by various youth groups over the holiday periods. There also seems to be no regard in relation to the Sainsbury Local Store where the popularity of this site surpasses available parking resulting in queues on the highway. This snts response to planning application 15/02300/OUTMAJ & 16/00106/OUTMAJ! 5 of 20 is also a popular destination for Park House students during break times where they go to pick up snacks, again creating a great deal of pedestrian traffic in the area. All these issues make an upgrade to Warren Road to bring more traffic from a different direction a dangerous proposition. We are also concerned that the proposed changes to Andover Road to facilitate these junction changes puts current users of Andover Road at risk. It seems perverse that a lesser standard is to be deployed for Andover Road in terms of pavement widths to those that Highways insist need to be in place for the main North/South link road within Sandleford itself, it is also noticeable that these lesser standards also pertain to Warren Road. This is an example where the needs of the new development appear to be put ahead of existing residents in the surrounding areas. It should be also remembered that Andover Road is a major gateway into Newbury and as such the look and feel of the approach should be preserved wherever possible. The destruction of the verges to facilitate the enhanced Sainsbury garage was regrettable and further erosion of green verges along this road, that also provide an important buffer between pedestrians and traffic should be avoided. We are also concerned that alteration to Andover Road where it is widened will have an impact given the steep camber to the side of the road. Again narrowing the pavement without addressing this issue could result in vehicles sliding off the road to the detriment of pedestrians. We also support residents in this area who are directly impacted by these proposals as to how they will access the A343 from their drives and side roads and for residents of Sunley Close as to how they will access Warren Road during busy periods. Given Sunley Close is a development made for retirees we are particularly concerned that access for emergency vehicles will not be compromised by these proposals. Going back to the flawed traffic analysis, the option that has Monks Lane and A339 as the only all vehicular access points shows the best impact in terms of lessening traffic volumes on the A343 which given the heavy pedestrian use of this area, in particular school children, raises the question of why the option of making Warren Lane all vehicular is being explored. We would urge the developers and Council to explore alternative options to give the development western permeability, in particular a route that heads south parallel to Andover Road to come out at a point somewhere near Wash Water. Such a route could be tied into the recent proposal by Gladman’s to build 85 homes in Wash Water and if such a route was explored, then proceeding with that application would make up for a shortfall in the delay of bringing the Western parcel of Sandleford on stream. It would also make a safer route for construction traffic bypassing as it would existing residential areas. We have not commented on the specific junction layout proposals as we understand that Donnington New Homes is still working on these with Council Officers and will wait to see what is planned to make this junction safe for all users. But the above reservations on the general principle of an all vehicular route at Warren Road still pertains. snts response to planning application 15/02300/OUTMAJ & 16/00106/OUTMAJ! 6 of 20 [A339 Access Road W14137_A009_Rev C] Whilst broadly in favour of an access road to the A339, it is inconceivable that anyone would introduce a new junction that did not incorporate access to the Household Waste Recycling Centre. We have not seen Highway’s proposals in this regard, however in principle we support their position that this junction should incorporate access to the HWRC. It would also seem preferable to make this junction a roundabout as opposed to a lights junction in an effort to keep traffic flowing in all directions. The documents state that this junction is to be funded by the Council from the central grant to enable land for housing development so why would the Council support a change that means over 2,000 new homes would have to make the return journey down to and up from the Swan Roundabout to access the HWRC? By this measure alone The Council is ensuring that any gains from new housing in terms of energy use is lost in carbon emissions from these extra car journeys and is non sustainable. If matters were to proceed without access to and from the A339 that incorporates access to the HWRC, then it is highly likely that the additional traffic trying to access the HWRC will leach onto the A339 causing queues on this major road. At peak time the amount of space within the site for queuing cars looking to unload their waste is already near the capacity of the site, and the site is already going to have to cope with the additional demand from the Racecourse development as well as some 500 houses from infill developments around south Newbury. Providing an access from the A339 to Sandleford that incorporates access to the HWRC offers the ability to build in additional waiting capacity for queuing cars as well as ensuring Sandleford traffic can reach the facility from internal roads as opposed to adding to the congestion on the A339. We also have concerns that the way that this access route has been designed into the overall development will fail in its purpose to take major traffic flows away from Monks Lane and other areas of the development. It would appear to link in to a minor road that leads directly to Monks Lane. There is a real risk that Council money will be spent on this access route that will fail to deliver any meaningful benefits in terms of traffic management with this configuration. We would favour an east/west link road running between Crooks Copse and High Wood to tie in with the other side of the Northern Parcel. This would necessitate a bridge to cross the valley at this point so to preserve the ecological status of this area. It would have the advantage however of allowing more south facing housing to be built with the solar gains that those properties will then enjoy. We also would urge the Council to fast track this route to the development so that it is complete to the eastern perimeter of parcel N1 before any construction starts. It could then be used as the route for construction traffic to the development again avoiding Monks Lane and the existing residential areas and streets used by school children. Ultimately this would speed the construction of the development as it would avoid the need to put time restrictions on traffic movements. We would urge the Council in consideration of these plans to remember existing residents who if not accounted for through these alternative routes to the development (the revised access from the A339 and the proposed route to Wash Water), face twenty years or more snts response to planning application 15/02300/OUTMAJ & 16/00106/OUTMAJ! 7 of 20 of heavy construction traffic which will make living in the area intolerable with the constant risk that would be posed to pedestrian and cyclists. [Monks Lane Western Access Roundabout W14137_A001_RevC] It appears problematic to put a roundabout in situ of a private drive and poses issues for delivery/removal vehicles to these properties (no access drawings have been provided for large vehicle movements to this drive). The phasing of this junction is also problematic in that N1 will be almost completely built before this access work begins with all those additional car journeys (from 300 new homes) along Monks Lane. It would appear sensible for both Monks Lane junctions to be built at the same time to minimise traffic disruption along Monks Lane even if the road from the N1 development to the roundabout is completed at a later stage. The Roundabout seems to have made no provision for cyclists, in its design. [Monks Lane Eastern Access T-Junction W14137_A_002 RevA] It appears that the proposal for this junction is a simple give way with no lights. It is difficult to see how any traffic will be able to leave in peak hours or school drop off/pick up times due to the constant stream of traffic along Monks Lane at these times. It also appears that this is now a minor route to the development only serving the eastern perimeter of parcel N1. This would suggest that the intention is to push the bulk of the developments northbound traffic through the western access, which will pose major issues in terms of traffic distribution in both directions along Monks Lane. Again we have major concerns about the impact this will have especially at school drop off and pick up times when Monks Lane is currently heavily congested with both pedestrian (school children) and car traffic as well as bus drop offs. Until a proper traffic survey is carried out to look at these impacts we have no further comment to make. The junction appears to have made no provision for cyclists. TRANSPORT As stated above it is impossible to make comment on the validity of the transport mitigation measures until a proper up to date traffic survey is completed that looks at surrounding areas that includes both: Essex Street, the traffic to and from the Monument parade of shops and the interaction with the pedestrian crossing; and Tescos and the Retail Park. These areas at the eastern and western northern peripheries of the Sandleford are both operating at near capacity with current levels of traffic and regularly cause bottlenecks at both ends of Monks Lane, Andover Road, Essex Street and the Sandleford link. Without proper mitigation putting more traffic on these areas will only make the current situation a lot worse. We have no solution for resolving the situation around Tescos and the Retail Park other than introducing a one way system that takes traffic out south along the A339 perhaps integrating with the new A339 access road, however we recognise such a solution would snts response to planning application 15/02300/OUTMAJ & 16/00106/OUTMAJ! 8 of 20 be fraught with difficulties, difficult to implement and likely to be unpopular with residents in those areas. Regarding the Monument parade consideration should be given to introducing a one way system with an exit going behind the Parade and The Gun to the northern end of Andover Road. Without such a solution this will remain a major bottleneck with traffic entering and exiting a narrow car park and with limited parking behind the stores. We are also very concerned that no modelling appears to have been done in relation to the construction traffic not only of the phased development itself but of other ancillary developments such as the expansion of Park House School and the expansion of Falkland Surgery both of which will necessitate construction traffic along residential areas. We know from the experience of the St Barts new build that this can be handled sensitively however the impact still needs to be factored in. [Monks Lane/Andover Road Improved Junction W14137- TRK001 - 006] We have grave reservations about the proposal to merge the double mini roundabout into a single roundabout at this junction. Our understanding is that this double mini roundabout was introduced originally to dissuade HGV traffic from utilising the A343 to access the town. Overall improvements to the Andover Road will encourage more traffic to use this route. This is of particular concern as the A343/A34 junction slip roads are notoriously short and there are real concerns about safety of accessing these roads if following a slow moving HGV vehicle up the hill. There is a particular concern at this roundabout proposal for northbound HGVs turning onto Essex Street where the tracking data shows HGV having to utilise the middle lane and to cross over the inside lane in order to make the turn. This is an obvious hazard to unwary users of the inside lane and seems to be designing in the potential for serious accidents. Again a survey of pedestrian usage would show that this area has excessive pedestrian use especially at pick up time from Park House School with students from both Park House and nearby St Bartholomew’s and any narrowing of the verges at this point would represent a safety hazard and again it has to be pointed out that the developer seems to be proposing narrower pavements outside of Sandleford than they are proposing for less busy traffic routes within the development. Finally we note that the Falkland Memorial is being put forward for a local listing as a heritage site and part of that has to be its unique setting. We would oppose anything that detracts from this important landmark in Wash Common. [Other Traffic Mitigation] We have no comments to make on the wider mitigation measures to address traffic going through the town centre as the data on which they are based is out of date and incomplete. We reserve our right to comment further when these proposals are fully developed. snts response to planning application 15/02300/OUTMAJ & 16/00106/OUTMAJ! 9 of 20 SUSTAINABILITY The applicant makes much of this being a sustainable development, however we would contend that this is not only not the case but also does not meet key requirements of the Core Strategy and SPD as adopted in March 2015. Bloor Homes in their Design & Access Statement and Planning Statement highlight recent government initiatives to encourage the building of new homes. In essence the Conservative Government has backtracked on green build initiatives and abandoned its commitment to Carbon Zero new homes by 2016 and instead, in an attempt to remove unnecessary red tape has committed new home builds to follow the lesser requirements stipulated in Building Regulations. The government indeed has gone further to instruct Local Authorities that they cannot impose further technical requirements on housebuilders beyond that stated in Building Regulations. In support of their application Bloor Homes state that it is the Government’s intent that builders should build therefore to Level 4 requirements (the current level of Building Regs) as opposed to the Level 6 that the former Carbon Zero target would require. However this is a very selective reading of the Governments position and they make clear (as stated in Bloor Homes own documents) that in relaxing the target on energy use in new home buildings they are giving housebuilders the flexibility to choose between energy efficient homes or to make up the deficit in efficiency with the use of renewable energy technologies. Bloor Homes have instead opted for Level 4 build with no commitment to deploy renewable technologies and as such are in breach of the Government guidelines. It is extremely disappointing that in the light of the Paris accord in December 2015 to ambitiously cut carbon emissions that Bloor Homes have instead opted to go for the minimum standards and shows gross corporate irresponsibility in doing so. What should be for them a templar development to show what standards can be achieved instead becomes a me-too development, a Bloor Home template, parachuted into an environmentally sensitive area. We also note that Bloor Homes commitment to sustainability extends to creating as many homes as possible with southerly aspects to maximise solar gain, and yet the density of housing is greatest on the north/south link road which seems at odds with this aspiration. If they were to introduce an east/west link to the A339 across the development then this would widen the opportunity for houses with southerly aspects. Bloor Homes commitment to green infrastructure also appears limited to within the development and this is also kept to a minimum standard. We note Highways and Transport comments in this regard and support their position on transport links however would go on to point out that spaces for bikes in garages is limited to a maximum of two irrespective of the size of house and we would want to see a commitment to provision of space for bikes that is commensurate with the number of bedrooms a house has, with an overall minimum of at least 2 spaces. We also note that there is no provision for improving the wider cycling infrastructure in Newbury and as already noted on all new junctions there appears to be no provision for cyclists. Whilst within the development there are cycle ways we note and agree with Transport assessment that these should be separate from the pedestrian footways and snts response to planning application 15/02300/OUTMAJ & 16/00106/OUTMAJ! 10 of 20 protected from car users. We would also want to see similar provision made along Monks Lane (the current shared footway along Monks Lane is too narrow for cycle and pedestrian traffic especially at school pick up times), and Andover Road as a bare minimum with the possibility of also looking at Rupert/Chandos/Wendan Road and Essex Street/Elizabeth Avenue/Valley Road and beyond for dedicated cycle routes. We note that the generous pathways for pedestrians within the site are not extended beyond the site where a number of the road ‘improvements’ narrows the space available to pedestrians (in particular Andover Road). In the Design & Access Statement and Planning Statement the applicant states on P20 of the latter document, Para 5.5 that the application will support sustainable economic development through the delivery of new homes, commercial space and infrastructure, thereby creating a thriving local plan. However the document does not state how many employment opportunities it will create and there appears to be no separate business area that was highlighted in the original proposals put forward with the Core Strategy (which was situated close to the HWRC). It seems hard to believe that the local centre will employ more than a small percentage of the total working population that will be living on Sandleford and so what substance is there behind this claim? Moreover the Local Centre is situated on the Central Parcel in the middle of the development - under current phasing it will be the last parcel to be developed and it will be at least six years before it is linked to the northern parcel - that is a long time to wait without a job to pay your mortgage! Rather than empty fatuous statements we would rather see concrete proposals for a sustainable development that offers genuine employment opportunities from the outset. This would include a proposal for the creation of a business park on the eastern periphery close to the HWRC and access to the A339. A possibility is that such a development could be handed over to a trust where the income from the rents could be used to fund the maintenance of the park and any surplus going to community projects in the area, on a model very similar to the Greenham Trust. ECOLOGY We have grave concerns as to how this development will impact on the ecology of this biodiverse site. We have not had the opportunity to go through all the documents in relation to this and so reserve the right to comment further, however a glance at the Breeding Birds section does not fill one with confidence when in the document it states in a table that the impact on the breeding population of Skylarks would be negligible. This in spite of the fact that the Central parcel is building on a field that last summer had at least five nesting pairs, and their other breeding area is to be turned into a country park where dogs will be free to roam and people will spread out enjoying summer picnics. WIthout a detailed plan as to how all this is to be managed it is hard to imagine how the bio-diverse nature of this area will not be severely compromised. However our concerns go beyond that. At the first public consultation with Bloor Homes I asked their ecologist why they didn’t open up Crooks Copse to the general public given that it was to be surrounded by housing anyway with all the detrimental impact that would have and instead cordon off High Wood which is a much more extensive woodland largely untouched by the development and therefore more likely to remain intact as a site for wildlife. The response was clearcut, Crooks Copse was a more ancient woodland and snts response to planning application 15/02300/OUTMAJ & 16/00106/OUTMAJ! 11 of 20 more important in terms of bio diversity than any of the other woodlands on the site. Given this how can it make sense to make this the only woodland to be nearly completely surrounded by housing with only a 15m buffer zone? We support the Woodlands Trust stance on this that greater emphasis needs to be made on the preservation of these ancient woodlands whose ecological landscapes have taken hundreds of years to develop and are surprised that the Wildlife Trust have not taken a more robust stance. We recognise that in order to accommodate 2000 homes in this environmentally sensitive landscape compromises will need to be made but impacting this woodland in this way does not seem to be the answer or if it is we need to see greater measures to mitigate the impact which will surely kill the wildlife in this area. One potential solution may be to not build on the south eastern corner of Parcel N1 (south of Crooks Copse) which would create a larger wildlife corridor and instead to build along the access road from the A339. Whilst this is out of scope of the Sandleford Partnership one has to look at the development of the area as a whole. Likewise it is not clear what the impact on hares will be who are regularly seen in areas that are to be built upon as well as land designated as parkland. We would urge the developers to look towards more rigorous measures to keep the human imprint away from sensitive areas which includes the Central Valley and the valley leading southwards from Crooks Copse. Any thoughts of locating play areas in these zones should be strongly resisted. We also have concerns about the use of attenuation ponds on the valley floors and the impact these would have on the Marsh/Bogland habitats in these areas. Far from promoting bio diversity these pond could destroy what is already there. There should be a formal path to the River Enborne. There are two reasons for this: i) there are precious few opportunities for people to access and enjoy the River Enborne and the parkland presents a unique environment to do this; and ii) with the opening up of the parkland and without a formal controlled route to the river, people are likely to create their own paths to the detriment of the wider woodland and habitat. DESIGN We have some major issues with the design of Parcel N1 which far from creating a distinctive local community appears to be a me-too package parachuted in from other Bloor Home developments. We are particular concerned with the heavy build of housing and apartments along the southern edge of Monks Lane which are out of character with the area and destroy the semi rural appearance of this road. The buildings need to be set back further whilst maintaining the existing hedgerow, in order to keep them within the Town’s building guidance. As mentioned above the density of housing should be revisited so that they are not concentrated on the north south axis of the development opening up more housing to solar gain. snts response to planning application 15/02300/OUTMAJ & 16/00106/OUTMAJ! 12 of 20 We have major concerns at the positioning of a LEAP at the southern edge of Crooks Copse in an area partially screened from housing and in an important ecological zone. This should be placed within the residential areas. Likewise we have major concerns regarding the location of the NEAP which is a playground for older children being situated to the east of Gorse Covert totally screened from nearby housing and it would appear in view of Sandleford Priory. This would seem to be a natural target zone for anti social behaviour and again its positioning should be re-considered. The new primary school in Parcel N1 is situated on the other side of the main north/south access road from the vast majority of the residential housing which means that school children will have to cross the main access road to get to school. This could be avoided if the school was positioned east of the main access road and situated beside Crooks copse which has the added advantage of providing a further buffer between this ancient woodland and residential housing and street lighting. As stated before we believe that building these homes to only Level 4 without renewable energy provision is counter to national guidelines and this needs to be addressed and Bloor Homes should make it an aspiration in their build programme to meet the Core Strategy intent to minimise carbon emissions from the site. There is a pedestrian entrance from Monks Lane that needs to be moved so that it is close to the existing pedestrian crossing at Ruperts Road so facilitating the use of this crossing. CS3 and the SPD are clear that the social and affordable housing needs to be pepper potted throughout the development. In Parcel N1 they are in clumps (with the apartment buildings in particular having a high percentage of affordable homes). We are particular concerned with the outline plan for the Western Parcel that includes an 80 unit easy care home centre which although welcomed will be counted towards the social housing and affordable housing quota which means that there will be virtually no other such housing in this sector. We are concerned that there is sufficient public infrastructure in place from Day 1 and that all houses lie within a 5 minute actual walk of a bus stop (as opposed to being within a radius of 400m). We also note along with the Transport response that there seems to be no provision for car sharing and would welcome not only 4 car shares for the new development but that this scheme is extended to the wider Wash Common community as well. IMPLEMENTATION There are many issues with the current phasing of the project and the resultant impact it will have on the surrounding neighbourhoods: Schools - the first primary school will not be delivered until 200 homes have been completed in Parcel N1 (well over half of this particular development) which means early occupants will be placing their children in other schools which are already at capacity and which result in additional car journeys. As currently constituted Parcel N1 has the new primary school to the west of the main access road. This means that when it comes to develop Parcel N2 and beyond all snts response to planning application 15/02300/OUTMAJ & 16/00106/OUTMAJ! 13 of 20 construction traffic will have to go past this primary school, or otherwise go via lesser residential roads which will create a logistical nightmare and create a difficult and dangerous environment for school children (indeed it might deter many parents from sending their children to that school). This can be avoided by a main east/west access road linking directly to the A339. We have no information on the timing of developments at either Park House School or Falkland Surgery as to when they will have more capacity which means additional car journeys from these early houses or further stretching the capacity of two institutions which already struggle without the additional disruption caused by their own build programmes. The local centre is phased for completion towards the end of the project as a result of which more pressure will be put on the Local Sainsbury and Monument parade of shops as houses are occupied with the resultant traffic flows. Tescos off Pinchington Lane and Sainsburys in the Town Centre will also face additional pressures as the build programme rolls out. As we have already stated Tesco is already at capacity during certain times of the day and so serious consideration must be given to how traffic is managed in this area and the adjacent retail park - both of which assume shoppers will be using their cars to access their facilities. The Central Valley Bridge linking the two halves of the development will not be completed until year six of the development which means until that point the two halves will be separate identities with the Northern Parcels forced to use Monks Lane and/or A339 access and the Western and Central Parcels forced to use the Western access wherever this is determined. Again this will cause major issues locally in terms of transport, direction of travel movements and supporting infrastructure (community halls, religious centres, local schools) that appears not to have been factored in. The phasing of the Country Park is unclear and needs to be carefully thought through so that undue pressure is not put on those areas that are released early to public use and the resultant usage that would be to the detriment on wildlife and ecologically sensitive areas, this is especially the case of Crooks Copse if residents interaction with this space is to be contained. The major issue however is the construction traffic on a development of this scale which is going to see a continuous stream of heavy vehicles to and from the site for a minimum of the ten years planned and maybe twenty years if all 2,000 homes are to be built. The Council cannot condemn existing neighbourhoods to this misery for such a prolonged period of time and as such alternative construction routes as we have suggested from the A339 to the northern parcels and Wash Water to the western and central parcels must be completed before any housebuilding is allowed to go ahead. OTHER CONSIDERATIONS The proposals utilise over an acre of land that is currently used by the Rugby Club as playing fields. The Core strategy states that provision of outside sport facilities is an important criteria in judging applications however there is no compensation or mitigation for this loss of outside playing fields. At the Planning Inspector hearings assurances were given that this would be looked at and mitigation considered. However not only is there no provision for additional outside sports provision within this site there is no provision snts response to planning application 15/02300/OUTMAJ & 16/00106/OUTMAJ! 14 of 20 anywhere to cope with the town’s expansion that in recent years has seen a net loss of land available and this must be addressed. There seems to be no provision for visitor parking to the Country Park outside of the Local Centre which presumably is to service the shops and other amenities in that area. Without specific car parking for the Country Park it is likely that surrounding residential streets will be used for parking with all the resulting problems that that could create. We see no provision for wider health concerns regarding ensuring there is sufficient health provision in terms of hospitals and other care requirements from the expansion of the town, and whether the NHS has been involved as to how this population expansion will be catered for. CONCLUSION It is our view that the application as currently constituted is incomplete, not fit for purpose and not compliant with either the Core Strategy or SPD. It is hoped that in working up new plans that Bloor Homes takes the various criticisms, not only of its plans but also about the process it has followed, on board and genuinely directly engages with all parties in devising a scheme that can win broad support not only from key stakeholders but the broader community as well. We also hope that Bloor Homes along with the Sandleford Partnership looks beyond the narrow confines of its profit line and looks to create a genuinely exemplar development that can be used as a model not just for other developments around the country but for future generations as well. Yours Sincerely Peter M Norman Spokesperson snts