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Bray Parish Council's Neighbourhood Development Plan

27/5/2015

2 Comments

 
Further to my blog dated 23rd May 2105, I must now add that I would vote against the Plan in its present form.  Residents can comment on the Draft Plan until the extended date of Friday 24th July 2015.

I have not been involved in the Bray Parish Council Neighbourhood Development Planning process except to criticise it.  This is because I wish to be free to object if I think it necessary.

Why do I not like it - as explained in the home page of this website - the way it has been established by government to allow a Neighbourhood to promote MORE development than the Borough Local Plan but never LESS development.  I recently learned that the proper legal title for a Neighbourhood Plan is a "Neighbourhood Development Plan".  So why are these mostly called "Neighbourhood Plans"?  I suppose because the latter seems more innocuous.

Although it is legally established that Neighbourhood Development Plans may promote MORE development than does the Borough Local Plan, it is only an option that the Plan could promote more development, it is not a requirement that it do so.  Thus, it could be acceptable to me if the Bray Parish Council's  Neighbourhood Planners would pay attention to what residents have indicated they want, and ensure that the Plan DOES NOT ALLOW development on the Local Plan identified areas 7A and 5C.  As we know, there was a clear indication from 88% to 97% of residents who responded to the HRA survey for the Local Plan, that these two areas must not be built on, and we know from the RBWM that their Local Plan intends that these areas will remain as Green Belt, not to be developed.

The RBWM statement of 26th February 2015 in connection with the Local Plan, rules out any development on all of the Bray Parish Green Belt, and this decision was supported by the three RBWM Bray Ward Councillors, and these councillors are still in place.  Perhaps part of the reason that residents voted for them was that these councillors had heeded Residents wishes regarding Areas 7A and 5C. The reporting RBWM Councillor for the Local Plan (not an RBWM Bray Ward Councillor) is also a Bray Parish Councillor. Two of the three RBWM Bray Ward Councillors are members of the Steering Committee for the Bray Parish Neighbourhood Development Plan and one of those is a Bray Parish Councillor.  As of the recent election, the third RBWM Bray Ward Councillor (the leader of the RBWM council) is now also a Bray Parish Councillor.  This being the case it is difficult to understand why the BPNDP as currently written still allows development on Bray Parish Greenbelt, especially on areas 7A and 5C.

The document issued to residents for comments by Bray Parish Council on 18th May 2015 (the "SHARE YOUR VIEWS" (SYV) document), states that "The Plan therefore does not propose any further housing development within Bray Parish", (also published on 21st May by the Maidenhead Advertiser) but the effect of this statement is only for the immediate future, it is not a permanent rule.  It does not align with the Bray Parish Neighbourhood Development Plan Vision Statement second sentence shown in the SYV and in the Draft Plan "We will respond to the housing needs of our communities with sympathetic development".  Further, it conflicts with the SYV Objective Number 7 "To ensure that housing changes maintain, and where possible enhance, the quality and character of the Parish so that future generations can enjoy the same or a better living and working environment." In addition, this concept of allowing housing development in the future is established by 11 of the Plan's policies BNP – GB1, GB2, BE1, BE2, BE3, BE4, BE5, BE6, BE8, TI1 and TI4.  Well, after all it is a NEIGHBOURHOOD DEVELOPMENT PLAN!

Regarding the Plan statement mentioned above "We will respond to the housing needs of our communities with sympathetic development", I ask how can the housing needs of our communities be differentiated from the housing needs of incomers?  If housing is built for people who live here, there is no restriction on these same people soon selling to incomers. Then there could be further pressure from residents for houses for them and this process of residents getting homes and selling to incomers, with subsequent residents pressure for more homes, would gradually fill our area with homes for incomers, whilst always increasing profits for developers.  This in Violet added 31 May 2015 - A comment has been raised about my remarks above re incomers.  My concern is not about incomers as such, it is just that I think it impossible not to have the situation I described above, so I feel that the phraseology used by BPNDP is disingenuous.

There is no policy statement that protects areas 7A and 5C, so I have suggested that the following be included as the first policy;

"This Bray Parish Neighbourhood Development Plan excludes from any possibility of development the areas identified in the RBWM First Preferred Options Consultation as Area 5C and Area 7A."

Reason for above policy - The RBWM’s conclusions on their First Preferred Options Consultation include that Areas 7A and 5C are Green Belt not for development, and this is supported by the HRA opinion survey for the RBWM Consultation, which found that 96.9% of Residents who responded said that they do not want any development on Area 7A,  and 88.1% said they do not want it on Area 5C.

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Another topic that has caused me concern is expressed in the Draft Neighbourhood Development Plan as follows;

"The Plan supports the planning and construction of a link road to the south of the M4 to alleviate passing traffic problems on the A330. The planned-for increase in traffic on the 'widened' M4 together with the substantial population increase resulting from housing development in the Royal Borough and in the adjacent areas North of Bracknell/Binfield are the main contributors to the issues, as well as commercial traffic passing though the Parish. A southbound link road would complement the busy A404(M) thus linking the M40 to the A4 and M4 and through towards the M3. The Plan supports the Thames Valley Berkshire Local Enterprise Partnership which has identified the need for a North-South link between the M40/M4 corridor and the M4/M3 area as a strategic priority to promote economic development in the region. Similarly the Plan sees this link as a main priority in securing a solution to the increasing Parish traffic problem and the method for improving intra Borough traffic flow. The link through the M4 should serve the A404M to encourage through traffic usage. It is noted that there are only two southerly exits on the M4 between Junction 4b (M25) and Junction 10 (A329M). The Plan supports the Highways Agency M4 SMART scheme currently under consultation."

You may have seen that no mention of the above appears in the SYV document.  It only contains a policy as follows;

BNP TI1  "As an objective of the Plan is the free flow of safe traffic throughout the Parish, any developments that have an impact on traffic movements in the Parish must provide a road infrastructure that is appropriate for all forms of transport allowing for regulatory requirements and forecasted increases in such movements."

It is clear to me that the aforementioned policy as written would allow the aforementioned link road. But there is no place in Bray Parish to put a link road from M4 J8/9 that would not cause great disruption to existing homes, and / or would cause extreme noise pollution and further gaseous pollution, especially if the said link road were to become a link to the M3.

I have therefore suggested a change to the Plan text as follows;

"The Plan supports the planning and construction of a new M4 motorway junction approximately mid-way between the existing M4 J8/9 and J10 with associated new North and South feeder roads.  This would encourage M4 traffic originating or terminating in these catchment areas, (in particular the Bracknell / Binfield areas), to avoid J 8/9 and the Bray Parish Area as a whole. This would alleviate passing through traffic problems in the Bray Parish Area. The planned-for increase in traffic on the 'widened' M4 together with the substantial population increase resulting from housing development in the Royal Borough and in the adjacent areas North of Bracknell / Binfield are the main contributors to the need for such roads, as well as commercial traffic passing through the Parish. The Plan supports the concept expressed by the Thames Valley Berkshire Local Enterprise Partnership in so far as a North-South link between the M4 and the M3 would improve traffic flow.  The new motorway junction and associated feeder roads we suggest here would assist in this regard."

And suggested a change to the BNP TI1 policy thus;

"BNP-TI1: As an objective of the Plan is the free flow of safe traffic throughout the Parish, any developments that have an impact on traffic movements in the Parish must provide an access road infrastructure to the satisfaction of Bray Parish Council and that is appropriate for all forms of transport allowing for regulatory requirements and forecasted predicted increases in such movements.  This policy does not advocate the building of any new major roads or modifications to the M4 8/9 junction."

__________________________________________

There are other areas of concern to me, but the aforementioned are the most important. Residents are invited to add their comments here, or in the Forum.
2 Comments

Bray Parish Council's Neighbourhood Development Plan

23/5/2015

0 Comments

 

The Bray Plan Steering Group whose website is www.brayplan.com is preparing, on Bray Parish Council's behalf, the Bray Parish NEIGHBOURHOOD DEVELOPMENT PLAN (NDP) commonly known as Bray Plan or Bray Parish Neighbourhood Plan.

The following links give further information about the development of such plans;

http://www.planningportal.gov.uk/inyourarea/neighbourhood/

http://planningguidance.planningportal.gov.uk/blog/guidance/neighbourhood-planning/who-leads-neighbourhood-planning-in-an-area/

http://planningguidance.planningportal.gov.uk/blog/guidance/neighbourhood-planning/key-stages-in-neighbourhood-planning/

Note that the Bray Plan Steering group is not a Neighbourhood Forum, as such groups are only valid in areas not covered by a Parish Council.  Where there is a Parish Council, should residents wish to have a NDP, it is the Parish Council that is accountable to residents for the proper development of such a NDP; such development to include obtaining the approval of residents.

Residents will know from the home page of this website that I have long had concerns about Neighbourhood Development Plans because the law allows such plans to promote MORE development but NOT LESS development than does the Borough Local Plan.  As it is, at this time, the new Borough Local Plan does not exist, however we have been told by RBWM's Bray Ward Councillors that the new Borough Local Plan will designate our local Green Belt Areas 7A and 5C as Green Belt not for development.

My concern on the Bray Parish Neighbourhood Development Plan is justified by the fact that one of the first things proposed to RBWM Planning by the Bray Plan Steering Group was that Area 7A be developed.  That proposal has since been withdrawn, but I remain concerned that some unacceptable loophole may be included in the Neighbourhood Development Plan.  (Area 7A is the land bounded by Holyport Road, Aysgarth Park, Ascot Road and Old Holyport.)

Legally it is the Bray Parish Council that is accountable to residents for the Bray Parish NDP, and it is clear from the Bray Parish Council minutes of meeting at the following link that Bray Parish Council has authorised or delegated the Bray Plan organisation to operate on their behalf.

http://www.brayparishcouncil.gov.uk/wp-content/uploads/2012/04/EO-Minutes-020215.pdf

It should be recognised though that the Bray Parish Council's ACCOUNTABILITY CANNOT BE DELEGATED.

The pdf downloadable from the button below is a copy of the information from the link on "Key stages in Neighbourhood Planning" and lists the main events and the order in which they must be carried out.

In the Bray plan website at http://www.brayplan.com/2015/05/08/chairmans-chat-may-2015/  we read that the draft plan is to be made available to residents from 18th May 2015.

This stage will be Step 3 in the "Key Stages" document "Pre-submission publicity and consultation".

Update as of 23rd May 2015 - The Draft Plan as at Stage 3 was issued on 18th May 2105 and my comments are available for download as a marked up copy extracted from the PDF document that Bray Parish Council issued.  These are on this website page "Local Items" "Bray Parish Neighbourhood Development Plan"

Key Stages in NDP development
0 Comments

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    Author

    Andrew Cormie is concerned about the possibility of adverse change occurring in the Holyport Area.  He is particularly concerned about the steady increase in traffic in this area, and the consequences of this - (noise, pollution, delays).
    He is concerned about the imposition on local residents of developments that will cause increases in traffic.
    He sees the HRA as a possible means to garner local opinion for all mattters that give concern to local residents.

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