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WOKINGHAM DISTRICT COUNCIL
LOCAL DEVELOPMENT FRAMEWORK
CORE STRATEGY EXAMINATION
Session 3: Arborfield Garrison SDL (CP19)
Statement of Barkham Parish Council (BPC) and Barkham Village Residents’ Association (BVRA).
1. This statement supplements the original representations by BPC (no. 1648) on 26 September 2008 and BVRA (no. 1747) on 27 September 2008.
2. BPC and BVRA are generally supportive of WBC's strategy of concentrating new residential development in a select number of SDLs, providing this is done in a sustainable manner.
3. We accept that it is appropriate that new residential development should take place on brownfield land released when Arborfield Garrison is closed. We are opposed, however, to further development on greenfield sites in the area. We believe this is consistent with Government Objective (ii) and Key Principle 1(v) in PPS7.
4. Whatever development takes place, it is fundamental for the quality of life of the local community to provide the necessary level of infrastructure in the area as the existing infrastructure, including roads, utilities and flood mitigation, are already overstretched. It is vital that the key transport improvements are put in place before construction of housing begins.
Contents
Page 2 Issue no. 20 – Is the capacity of the SDL correct ?
Page 4 Issue no. 24 – Will unacceptable transport effects result ?
Page 8 Issue no. 28 – Other issues for individual SDLs will cover matters such as flood risk, ecological effects, proposed boundary revisions etc
Page 8 - Flood Risk and Sewerage
Page 11 - Arborfield Garrison SDL greenhouse gas emissions
Page 12 - Proposed boundary revisions (Barkham Square Park)
Issue no. 20 – Is the capacity of the SDL correct ?
1. In the case of the proposed Arborfield Garrison SDL, we believe that the scale of the new development should be 2,500 rather than 3,500 new dwellings for the following reasons:
● the allocation of 3,500 new houses appears to be arbitrary;
● it ignores the existing housing on the Garrison site.
2. The original draft South East Plan, the Report of the Examination-in-Public Independent Panel on the soundness of the South East Plan and the Secretary of State's proposed changes published on 17 July 2008, all contemplate the building of 2,500 new dwellings at Arborfield Garrison SDL by 2026 rather than 3,500 dwellings.
In addition, the TBH SPA Technical Assessor in his report to the Panel dated 19 February 2007 recommended (in paragraph D.(i)) that housing levels within the area affected by the Thames Basin Heaths SPA should not be increased at that stage above those indicated in the draft South East Plan unless it could be demonstrated that any additional housing can be accommodated outside the 5km zone around the SPA.
The Assessor's Report (paragraph 9.2) also recommended against allocating more housing within the area until such time as it had been more firmly established that the provision of SANGS, together with other measures, would be sufficient to mitigate the impact on the SPA. The boundaries of Arborfield Garrison SDL fall well within the 5km zone.
3. It appears to have been largely overlooked that the 3,500 new dwellings proposed to be built at Arborfield Garrison are in addition to the existing housing. The only mention in the Submission Core Strategy is in paragraph A7.2(e) of Appendix 7 (page 94), where the existing housing is described as "peripheral".
The peripheral housing currently comprises 882 dwellings: 312 MoD houses, 493 private houses on land adjacent to the A327 released by the MoD and 77 houses on the new Poppy Fields development.
Applying a multiplier of 2.55 persons per household (average Wokingham household size in 2001), the WBC proposals would result in a settlement of some 11,220 people (3,500 + 900 houses) per the Submission Core Strategy by the end of the plan period (which in turn would have implications for the separation of the SDL and Wokingham).
4. The infrastructure supporting the Army housing (312 dwellings) was not constructed to WBC standards. Has WBC made any provision for upgrading this infrastructure to comply with current WBC standards ?
5. It is also unclear whether part of the existing barracks is likely to be converted into flats rather than offices. If so, would any such accommodation be included within the proposed allocation of 3,500 dwellings ?
6. Policy CP19.1 reflects the requirement in CP5 that at least 35% of new dwellings to be built within SDLs will be affordable. Such a rate of provision within Arborfield Garrison SDL would alone be enough to double this type of ownership within Wokingham Borough and it would require funding of £185 million (i.e. 1,225 houses at unit cost £150,000). Applying the same 35% ratio for all new building across the whole borough would require funding of around £700 million. Does 35% remain a realistic target considering the changed economic environment since CP5 was formulated ?
7. Conclusion
(a) What part of the DPD is unsound ? - CP19.1.
(b) Which soundness test does it fail ? - not justified.
(c) Why does it fail ?
(i) The scale of the settlement proposed in the Submission Core Strategy lacks justification. There is no explanation of the increased scale, which appears to be arbitrary (cf. the different SDL housing allocations in the special summer 2008 edition of 'Wokingham Borough News').
(ii) CP19.1 ignores the existing housing on current and former MoD land at the Garrison which would result in a settlement of 4,400 rather than 3,500 dwellings.
(iii) A settlement on the Garrison site on this scale lacks sustainability, including unacceptable transport effects and downstream flood risk, and is likely to generate disproportionate carbon emissions at variance with CP1 because of the distance of the SDL from other retail centres and employment areas.
(d) How the DPD can be made sound ?
By ensuring that the housing allocation for Arborfield Garrison SDL conforms with the allocation which was considered to be sound in the context of the South East Plan and the recommendations of the TBH SPA Technical Assessor.
(e) The precise change/wording that is being sought.
Sub-paragraph (1) should be amended to read:
"1) Phased delivery of around 2,500 new dwellings, of which at least 35% (?) will be affordable under policy CP5;".
Issue no. 24 – Will unacceptable transport effects result ?
1. Congestion along B3349 Barkham Road
(a) B3349 Barkham Road is the main link between Arborfield SDL and Wokingham. This route, which is supposed to be a residential road, is already heavily congested at peak times and carries considerable through traffic, including heavy goods traffic accessing the Fishponds Road industrial estate (off Molly Millars Lane).
The following points should be noted:
(a) Already there is considerable development taking place along this road including "backlands" developments in both the Barkham and Wokingham sections of the road. Further development is anticipated when the Guide Dogs premises at Folly Court are vacated and also in the vicinity of the level crossing on the cricket field site.
(b) There is a narrow bridge near the Langley Common end of the road which has single file traffic only. This is a current bottleneck which would need to be resolved.
(c) The main east-west and north-south routes through Barkham are combined along a ⅓ mile stretch of the B3349 Barkham Road between Coppid Hill and The Bull. These junctions cause considerable congestion at peak times.
(d) There is little possibility to improve the most congested junctions along Barkham Road, including Bearwood Road, Old Woosehill Lane and Molly Millers Lane owing to the proximity of houses.
(e) Barkham Road enters Wokingham Town Centre at the level crossing. This is a notoriously congested junction as it interfaces with the main northbound route through Wokingham (A329) and with the station’s entry/exit. The proximity of a pelican crossing and the level crossing serve to compound the chronic congestion at this junction.
2. Level-crossing
The following specific points should also be noted regarding the level crossing:
(a) The normal day time service through the level crossing comprises a minimum of 6 services each way, with additional peak hour services and extra freight and through trains. Based on a calculation of 2 minutes per train this means that the crossing is closed for upwards of 24 minutes in every hour. (Observation suggests this estimate understates the closure).
(b) The number of trains passing through the level crossing is likely to increase within the timescale of the WBC Core Strategy. Plans are already progressing to increase capacity at Reading station and there is a proposal to route the Airtrack service between Reading and Heathrow through Wokingham. In addition there is demand for more capacity to Waterloo and on the Guildford/Gatwick service at least to increase the frequency of the Crowthorne/Sandhurst stopping services to half hourly. These changes would increase frequency to at least 8 and may be as high as 10 services each way per hour. This could increase level crossing closure up to 40 minutes per hour.
(c) At this level of rail services, the B3349 ceases to be a sustainable traffic route even for local traffic – it is imperative that the level crossing is replaced by a bridge, or an alternative traffic scheme, before significant development can take place to the west of Wokingham.
GVA Grimley, in their own proposals, admit that Barkham Road will be operating at capacity in the morning peak, though arguably this is already the case.
Assumptions regarding traffic growth seem optimistic (in terms of limiting growth). There are a number of assumptions that amount to wishful thinking.
It is not realistic to expect as high a level of "internalisation" as is suggested. Providing facilities and services within Arborfield SDL, though not necessarily to be discouraged, are likely to generate as least as much inbound movements as they will save outbound flows. Examples include the following:
(a) Employment
Modern social and employment patterns are not conducive to people living within the immediate vicinity of their employment. The predominance of dual income households means that it is commonly the case that both wage earners are employed in different places. As a norm at least one wage earner will have to travel.
A likely outcome is that households will be situated by choice in a locality that is between the workplaces of the two wage earners. Anecdotal evidence indicates many cases in the Wokingham area where, for example, one works in Guildford and the other in Swindon.
Fluidity of employment structures also results in wage earners frequently having to change their place of work, whether or not within the same company. The consequence is an explosion of long distance commuting, as one member of a household may not wish to disrupt the commuting structure, or indeed the education, of other family members.
Fluid social structures also give rise to long distance commuting: where families breakdown and are recreated with different partners, it is inevitable that many sub-optimal commuting patterns will result.
(b) Secondary Schools
The proposed secondary school will serve the whole of south and west Wokingham, not just Arborfield SDL. This suggests that the great majority of pupils will have to travel into the SDL. It is certain that a significant proportion of these journeys will be by car, given the distances involved and the scatter of settlement.
(c) Supermarkets
It is suggested that a supermarket should be located in Arborfield SDL. This will inevitably draw on a larger catchments area. Consumer choice will also mean that shoppers do not use always the nearest supermarket.
4. Personal travel requirements
It is essential that a high quality/high frequency bus service be provided, and that the layout of the settlement should be designed with this in mind. However it is not realistic to anticipate a high level of bus ridership for a number of reasons. The complexity of personal travel requirements is not compatible with the limited number of destinations that can be provided by a bus service. For example:
● Employment is likely to be in a wide variety of locations including, amongst others, Greater Reading, Bracknell, north Hampshire, Slough, Heathrow, west London and central London.
● Shopping will be spread among a number of centres including Reading, Bracknell, Camberley, Basingstoke and Guildford.
● Similar complex patterns will emerge for higher education, entertainment and social needs.
The design of the settlement to include cycleways and footpaths is to be encouraged. However these will absorb only a limited proportion of total journey numbers (and an even lower proportion of journey miles) for much the same reasons as outlined in the previous paragraph. For similar reasons car sharing is also unlikely to make significant reductions in car usage.
5. Conclusion
(a) What part of the DPD is unsound ? - CP19 and Paragraph A7.7 of Appendix 7 (page 96).
(b) Which soundness test does it fail ? – not effective.
(c) Why does it fail ?
(i) There is no infrastructure proposal within the Submission Core Strategy (whether in CP10 or elsewhere) to replace the level-crossing in Barkham Road. Therefore it is unrealistic to base extensive development at Arborfield Garrison on the premise that the B3349 Barkham Road can provide a sustainable access corridor into Wokingham.
(ii) There is a lack of commitment in the Core Strategy to providing the improved road links deemed to be necessary to support sustainable travel. In particular, there is no reference in CP19, and a non-committal reference in sub-paragraph A7.7(a) of Appendix 7, to the need to build a strategic link road from the A327 to the A33 to provide better access from the SDL to Reading and the M4 (J11) and bypassing Arborfield Cross and Shinfield.
(iii) The provision of enhanced bus services between Arborfield Garrison SDL and Reading and Wokingham/Bracknell is essential if sustainable travel is to be delivered, but Paragraph 4.83 of the Core Strategy merely speaks of the need for "improved public transport services" to serve the SDL, while sub-paragraph A7.13(a)(iii) of Appendix 7 refers only in general terms to "improvements to the quality and frequency of public transport services along any part of the network".
(d) How the DPD can be made sound ?
(i) By providing for the removal of the level-crossing on the Barkham Road adjacent to Wokingham station which will remove a major obstacle to the deliverability of improved transport capacity on the western side of Wokingham and thereby support the sustainability of Arborfield Garrison SDL.
(ii) By committing to provide a strategic link road from the A327 and the A33. This will make the SDL more sustainable as a link road will provide better access to Reading and the M4 and mitigate traffic congestion on the A327 in Arborfield Cross and Shinfield.
(iii) By committing to secure binding agreements to provide and fund an enhanced bus service to Reading (at least 4 services per hour), Wokingham and Bracknell (both at least 2 services per hour). For the reasons discussed above, it should be accepted, however, that this is only a partial solution to the transport needs of the SDL.
(e) The precise change/wording that is being sought.
(i) CP19 should be amended by the addition of the following paragraphs:
"9) Removal of level-crossing adjacent to Wokingham station to improve transport capacity along the B3349 Barkham Road; and
"10) Construction of strategic link road between the A327 and the A33 to provide better access to Reading and Junction 11 of the M4 motorway".
(ii) Consequential amendment to sub-paragraph A7.7(a) of Appendix 7.
(iii) Paragraph A7.7 of Appendix 7 (page 96) should be amended by the addition of the following paragraph:
"i) There will be high quality/high frequency bus services linking the SDL with Reading, Wokingham and Bracknell".
Issue no. 28 – Other issues for individual SDLs will cover matters such as flood risk, ecological effects, proposed boundary revisions etc - Flood Risk and Sewerage
1. The north of the Arborfield Garrison SDL site drains into the River Loddon while the south of the site drains into the Blackwater River, which in turn feeds into the Loddon.
2. As regards the risk of run-off from the new development exacerbating the potential for flooding downstream, sub-paragraph A7.13(e)(ii) of Appendix 7 to the Submission Core Strategy (page 98) simply refers to the need for flood mitigation measures in relation to California Country Park and Longmoor Bog SSSI.
3. The representations by GVA Grimley (no. 1313) in respect of the Submission Core Strategy include a 'masterplan' for the development of Arborfield Garrison SDL. Section 3 of the GVA Grimley Site Appraisal Annex B) deals with Flood Risk. It omits specifically to address the issue of downstream flooding on the basis that SUDS technology will ensure that run-off will be no greater than before the site was developed as required by PPS 25.
4. The proposals overlook the fact that there is a long-standing flooding problem downstream from the Arborfield Garrison site along the River Loddon which routinely causes the closure of the two main roads from Wokingham/Arborfield to Reading (A329 and A327) whenever there is very heavy rainfall.
The most recent closure of the A329/A327 trunk roads on account of flooding was earlier this month on 10 and 11 February.
5. The major traffic arteries which are routinely impassable when the River Loddon floods after very heavy rainfall are:
(a) A329
The Loddon Bridge roundabout where the B3270 Lower Earley Way meets the A329 Wokingham Road/Reading Road (SU715767), by Showcase Cinema/Park & Ride (which also flood).
(b) A327
The Arborfield Road/Reading Road from Arborfield Cross to Shinfield between the bridge over the River Loddon (Arborfield Bridge) and the Magpie & Parrot (SU678743).
(c) The unclassified road called Mill Lane between the B3030 Mole Road/King Street in Winnersh and the B3270 Lower Earley Way, by Sindlesham Mill (SU705767).
6. When the two main routes from Wokingham/Arborfield to Reading are closed by flooding, the only viable route by road from the west side of Wokingham to Reading is to drive eastward along the A329 through the centre of Wokingham towards Bracknell and to join the end of the A329(M) motorway spur on the eastern edge of Wokingham at Coppid Beech Roundabout.
7. There is no assurance that SUDS technology will be able to ensure that run-off will be no greater than it was before the development of the SDL. Evidently, climate change is also predicted to bring an increase in the intensity of rainfall over the Thames region of 30% by 2085.
The run-off from a large scale development on the Arborfield Garrison SDL site therefore poses the risk of exacerbating the incidence of flooding downstream closing the A329 and A327 into Reading whenever there is very heavy rainfall with consequent major traffic dislocation.
8. Paragraph 4.83 of the Submission Core Strategy says that: "The delivery of the site may need to await adequate capacity in the sewage network as highlighted in the SFRA".
In fact, Section 4.6.4 (Thames Water advice for SDLs) of the SFRA concludes as follows in relation to Arborfield Garrison SDL:
"Significant growth will necessitate a major upgrade of the works. The nature of the site is such that expansion may be too difficult and alternative options may be required such as a new sewage treatment works or pumping away to another sewage treatment works. These options are subject to cost, practicality and stakeholder requirements. The provision of a new treatment works would take between 8 and 10 years from inception to completion".
9. Conclusion
(a) What part of the DPD is unsound ? - Paragraph A7.13(e) of Appendix 7 to the Submission Core Strategy (page 98).
(b) Which soundness test(s) does it fail ? – not effective.
(c) Why does it fail ?
The proposals for the development of Arborfield Garrison SDL:
(i) fail to recognise that there is an existing downstream flooding problem along the River Loddon with consequent closure of the two main traffic arteries from Wokingham/Arborfield to Reading (A329/A327) and associated major traffic dislocation, which needs to be resolved as a preliminary to developing the site;
(ii) do not deem it necessary to address mitigating the risk of exacerbating the existing propensity for downstream flooding along the River Loddon;
(iii) understate the measures required to provide adequate sewerage capacity for a development on the scale proposed.
(d) How the DPD can be made sound ?
(i) By recognising that there is an existing downstream flooding problem which impacts the strategic transport network between Wokingham/Arborfield and Reading which needs to be resolved and taking measures (which may include rephasing development at Arborfield Garrison SDL) to mitigate, or at least not to exacerbate, the problem.
(ii) By formulating detailed plans for overcoming the lack of sewerage capacity.
(e) The precise change/wording that is being sought.
Paragraph A7.13(e) of Appendix 7 to the Submission Core Strategy (page 98) should be amended to read:
"e) Water/drainage/sewerage:
i) Adequate sewerage capacity, including new or alternative treatment works if necessary
ii) Any necessary flood mitigation measures in relation to:
- the A329, A327 and Mill Lane; and
- California Country Park and Longmoor Bog SSSI".
Issue no. 28 – Other issues for individual SDLs will cover matters such as flood risk, ecological effects, proposed boundary revisions etc - Arborfield Garrison SDL greenhouse gas emissions
1. It has to be said that the proposal to build dispersed settlements that cannot easily be serviced by public transport does not sit comfortably with the Government target to reduce greenhouse emissions by 80% by 2050.
2. Pegasus Planning, who are advising the promoters of the Barkham Square Park proposal, indicate that through some adjustments to the configuration of Arborfield Garrison SDL, carbon emissions can be reduced by 4 million kg over 20 years. Based on their own figures this is a reduction of only 5%, but conversely, using the same figures, the SDL is increasing emissions by 80 million kg over 20 years. (The figures used by Pegasus are in fact misleading as they are calculated on straight line distances, not driving distances, use an unrealistic distribution of travel destinations and take no account of congestion: the saving suggested by their proposal therefore is spurious).
3. Conclusion
(a) What part of the DPD is unsound ? - CP19
(b) Which soundness test does it fail ? – not effective.
(c) Why does it fail ?
The Submission Core Strategy fails to set a target for the reduction of greenhouse gases from transportation or demonstrate any realistic strategy for reaching such a target.
(d) How the DPD can be made sound ?
In order to work towards a meaningful reduction in carbon emissions, development would have to take place:
(i) much nearer to the main regional centres for business, shopping and education services, and/or
(ii) adjacent to existing rail arteries that are able to provide high frequency services and/or
(iii) new rail or light rail routes would have to be constructed.
(e) The precise change/wording that is being sought.
CP19 should be amended by the addition of the following paragraph:
"Provision of public transport modes serving the SDL designed to reduce greenhouse gas emissions referable to measurable targets".
Issue no. 28 – Other issues for individual SDLs will cover matters such as flood risk, ecological effects, proposed boundary revisions etc - Proposed boundary revisions
Site allocation representation no. XXXIV (Land North of Arborfield Garrison) proposes to shift the SDL northwards by the incorporation of 164 acres at Barkham Square Park (BSP). BPC and BVRA have examined the BSP evidence and have concluded that it does not constitute a Reasonable Alternative to the Submission Core Strategy. Detailed reasons for these conclusions are set out in the Memorandum attached to BPC’s letter dated 15th December 2008.