BLP Regulation 18 Consultation - December 2016

Maidenhead and Cox Green Maidenhead Neighbourhood Plan Group (M&CGNP) 

We are concerned that our response is being submitted without having yet seen any Supplementary Planning Documents giving supporting evidence and reassurance that the infrastructure delivery plan will be able to handle the c45% increase in the overall population of Maidenhead and the trebling of housing planned for the town centre. 

We are supportive of Policy SP1 - Spatial Strategy for the RBWM and  5.10.3 – “ The Localism Act 2011 promotes community-led proposals which are driven by local residents, rather than the Council or commercial interests. The Borough wishes to encourage residents to engage directly in the planning of their communities and will support in principle community-led proposals which meet an identified need and have the agreement of the local community. The preferred method of this engagement will be through Neighbourhood Plans.” 

However, it is important that the BLP has a fundamental policy that takes into account the weight of the M&CG Neighbourhood Plan.  The National Planning Policy Framework includes a presumption in favour of sustainable development and the Planning Inspectorate has published a model wording which it considers, if incorporated into a draft Local Plan submitted for examination, will be an appropriate way of meeting the expectation for clear policies to guide how the presumption in favour of sustainable development will be applied.   The model wording for the policy is: 

National Planning Policy Framework – Presumption in favour of sustainable development. 

When considering development proposals the Council will take a positive approach that reflects the presumption in favour of sustainable development contained in the National Planning Policy Framework. It will always work proactively with applicants jointly to find solutions which mean that proposals can be approved wherever possible, and to secure development that improves the economic, social and environmental conditions in the area. 

Planning applications that accord with the policies in this Local Plan (and, where relevant, with policies in neighbourhood plans) will be supported unless material considerations indicate otherwise.

Where there are no policies relevant to the application or relevant policies are out of date at the time of making the decision then the Council will grant permission unless material considerations indicate otherwise – taking into account whether:

 

  1. Any adverse impacts of granting permission would significantly and demonstrably outweigh the benefits when assessed against the policies in the National Planning Policy Framework taken as a whole; or 
  1. Specific policies in that Framework indicate that development should be restricted.

 

The Inspectorate’s model wording means that every single planning application has to have that policy applied, ergo relevant neighbourhood plan policies are included every time, and we would therefore, suggest that the wording above is included within the BLP together with this addition: 

The National Planning Policy Framework requires a presumption in favour of sustainable development.  Local Planning Authorities should regard this principle as a golden thread running through plan-making and decision taking.  The Local Plan defines the strategic objectives towards this aim through the policies and supporting guidance documents contained within this document.  Neighbourhood Plans provide more locally distinctive development policies forming part of the statutory development plan for the area and will be used alongside the Local Plan as a key consideration to assist in the determination of planning applications.

Tall building height

The Maidenhead Town Centre Area Action Plan (AAP) was developed over a four-year period, widely consulted and inspected before adoption in 2011.  However, the draft BLP proposes that the housing target will now be three times the AAP figure and increased to around 2,500 and has removed all the AAP’s  limitations on maximum building heights and the location of tall buildings. 

We are strongly opposed to this as the evidence within the Maidenhead Town Centre Capacity Study undertaken by Lambert Smith Hampton (LSH) for RBWM and published in November 2015,  concluded that Maidenhead Town Centre could accommodate 3,924 housing units, a massive 57%  more than the 2,500  housing target without breaching existing AAP policies, which already have considerable flexibility.    What is more, LSH also stated that the 3,924 units could be achieved, with the average height being just 9.3 storeys in the densest site (West Street) and so well within the existing AAP guideline of 12 maximum. 

On page 35 of the BLP – Spatial Strategy –  Option 3   “To permit building to a level that strikes a balance between the projected population and economic development needs and the environmental impacts, including some buildings in the Green Belt.”   This statement is also of concern as there is no limit to the height permitted, and states that “economic development needs” are a consideration.  

Therefore we, conclude that it is illogical and unnecessary to abandon all limits on tall buildings in the town centre, and the AAP Policy MT6 on Tall Buildings  should be reinstated.  The LSH Capacity Study to be attached to strengthen our conclusion, as this key study was not mentioned anywhere in the BLP’s evidence base. 

Car Parking

Car parking in Maidenhead for both office workers and residents is a concern.

There is currently no further capacity for additional office parking, and there is evidence that this situation is having a negative effect on attracting new companies to the Town.  So with our car parks at capacity and we understand a potential 30% increase in commuters as a result of Crossrail, with no supporting documents, we are concerned that unless parking, accessibility and infrastructure issues are addressed, Maidenhead’s attractiveness will diminish.   

Maidenhead’s vehicle ownership is higher than average (ONS 2011), and accepting that even London commuters will own a car for weekend travel and additional spaces will be required for retail and Crossrail, proposed residential units throughout the town will need car parking spaces which reflect these increases.  This matter will also be addressed in the M&CGNP. 

But with no supporting documents yet, we are concerned that unless parking, accessibility and infrastructure issues are addressed, Maidenhead’s attractiveness will diminish.

Housing Mix  (HO2)

A policy is required to determine and deliver the ideal balanced mix of house types within Maidenhead. Currently, market forces are delivering an oversupply of new-build flatted developments. The most recent national survey indicates flats constitute 19% of the total housing stock. The 2011 census showed Maidenhead's housing stock with 24% flats.

Since then there has been a substantial increase in the proportion of new build residential planning permissions for flatted developments - more than 40%.

The SHMA identifies the size of a family and life stage as the driver for house type and size requirement. It is clear that whilst flats may be suitable for single persons, young couples and retirees, they are not satisfactory for families with young children. Families require a sense of space and community rarely offered by flatted developments. There is a risk that couples will have to move out of Maidenhead when they have children - because of the undersupply of "family homes".         Flatted developments are a short term fix to help deliver house number targets and will result in an oversupply because of short-term expediency. 

With the very high cost of homes in Maidenhead, and the desire to both attract and keep young families and help residents who want to move up the property ladder, a range of affordable units outside of the town centre is very much needed.

Therefore maisonettes, terraced and town houses, semis and 3 and 4 bedroom family houses with amenity space would all be preferable to flats. Bungalows are also required to provide an option for older residents, who can move from oversized family homes, thereby freeing up the housing supply chain.  Researchers say 18% of Britain’s property market would be unlocked for others, and found 3.3 million older people were in oversized properties worth a total of £820 billion.

Bungalows do not necessarily require more land because, with new build-saving designs, the footprint for a bungalow is less than 70sqm, the same as an average two-bedroom home.

The balance of our housing stock is critical in delivering accommodation that meets the future needs of residents, and the M&CGNP will be addressing this.


Size of Dwellings  (HO6) 

There is an ongoing tendency for living space to be reduced as developers seek to maximise the number of dwelling units from each development. The clearly defined "Nationally Described Space Standard" is intended to ensure that living space is adequate for the intended number of occupants.

Many current applications include dwellings that fall below the minimum space standard - especially flats. The minimum space specification should be enforced as a planning requirement. It is not satisfactory to assume that developers will adhere to space standards voluntarily, and there is no point in having standards if they are not enforced by the planning authority.


Arts and Culture 

The AAP recognised the York Road Opportunity Area (YROA) as the Town’s “civic and cultural quarter”.  It also identified the need to revive the town's reputation as a "destination", and we would like to see Maidenhead included as a destination in section 10.2 (Visitors and Tourism). 

The Waterways is certainly one element and plays an important role in Maidenhead’s future.     Not only will it provide a “waterside” culture to the Town and all that that brings, but it is an integral part of the regeneration of the Town centre with not only new developments already being built either side there, but also many site allocation proformas to the north and south of the town that adjoin, or are very close to the waterway route. 

All waterside site allocations in the BLP should be required to embrace the Maidenhead waterway, directly contribute to its funding and follow the design principles set out in the 2009 Maidenhead Waterways Framework SPD on such matters as buffer zones, active frontages, public access and pocket parks.  Maximising the amenity aspects of the waterway project is probably the best, and maybe the only way in which a worsening shortfall in public open space can be avoided as Maidenhead grows.

 The detail of our full response from the Cox Green & Maidenhead Steering Group to the consultation is on the portal for the BLP.

 Yours sincerely,

 

Philip Love - Chair,  Richard Davenport, Roger Panton, Martin McNamee, Ian Rose, Mike Copeland, Stephen Hedges, Ian Harvey.

 

 Maidenhead and Cox Green detailed submission  Very large file

 


 

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