Neighbourhood Plan

Crowthorne Parish

CROWTHORNE PARISH NEIGHBOURHOOD PLAN

2018-2036

CONSULTATION STATEMENT

Published by Crowthorne Parish Council under the Neighbourhood Planning (General) Regulations 2012 (as amended)

July 2019

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CONTENTS PAGE

1 CONSULTATION PROCESS 3

2 KEY THEMES FROM CONSULTATION 8

3 REGULATION 14 CONSULTATION FEEDBACK SUMMARY 11

Appendix A Examples of publicity material used to promote engagement events

Appendix B Public notice and text of letter/email sent to statutory bodies and other interested parties regarding Pre-Submission Consultation

Appendix C Regulation 14 Report of ONeill Homer dated May 2019 summarising comments and responses to Pre-Submission CNP consultation from statutory consultees, developers/landowners, other interested organisations and the local community

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1 CONSULTATION PROCESS Introduction

1.1 This Consultation Statement has been prepared to fulfil the legal obligations of the Neighbourhood Planning Regulations 2012 (as amended) in respect of the Crowthorne Neighbourhood Plan (CNP).

1.2 The legal basis of this Consultation Statement is provided by Section 15(2) of Part 5 of the 2012 Neighbourhood Planning Regulations which requires that a consultation statement should:

• Contain details of the persons and bodies who were consulted about the proposed neighbourhood development plans;

• Explain how they were consulted; • Summarise the main issues and concerns raised by the persons

consulted; and • Describe how these issues and concerns have been considered and,

where relevant addressed in the proposed neighbourhood development plan.

1.3 The policies contained in the CNP are as a result of considerable interaction and consultation with the community and businesses within Crowthorne Parish. Work has involved engagement with community groups over approximately three years, as well as public meetings and events. This has been overseen and coordinated by the CPNP working group which was formed to lead the CPNP. Views and interactions from this process led to the Vision and Objectives in section 5 of the CNP, and subsequently therefore form the basis for the key policies is set out in section 5 of the CNP.

Organisational structure of the CNP

1.4 The structure put in place to lead the CNP process was a small working group focusing on work across the range of themes that formed the basis of the draft NP. This steering group included representatives from Wokingham Without Neighbourhood Plan because there is a nexus between the two plans which are being prepared at the same time, as, despite them being individual Parishes and falling under different Borough Councils (Crowthorne is in Bracknell Forest Borough and Wokingham Without is within Wokingham Borough) both parishes fall within the urban village area of Crowthorne.

1.5 The CNP working group met regularly throughout the process.

1.6 The minutes and notes of meetings were made available on the Crowthorne Parish Council website under the Neighbourhood Plan section. http://www.crowthornepc.org.uk/neighbourhood-plan.html

Public events and consultation activities

1.7 The following timeline documents the procedural steps, consultation and engagement activities undertaken.

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Timeline 2015-16 – Wellington College Community Service survey compiled by students and carried out in Crowthorne village. Results presented to CPC in March 2016.

March 2016 – CPC resolved to apply for the Crowthorne Neighbourhood Area to be designated.

15 June 2016 - Neighbourhood Area formally resolved by Bracknell Forest Council. Crowthorne Parish Council is now able to commence work on producing a Neighbourhood Plan.

13 July 2016 – letter to identified stakeholders to nominate representatives to join the Working Group.

13 September 2016 – First Working Group meeting. Notes from meeting available on CPC website.

Winter 2016 Edition Crowthorne Eye – distributed to every household in Crowthorne giving an update on the CNP.

August 2017 – Appointment of ONeill Homer planning consultants (formerly rCOH).

Summer 2017 CPC Newsletter – Update provided to residents that NP Working Group has met. Call to residents for more members to join the Working Group.

11 October 2017 – Working Group meeting with appointed planning consultants ONeill Homer. Notes from meeting available on CPC website.

20 October 2017 – CPC Facebook post inviting local residents and stakeholders to develop NP for Crowthorne.

8 November 2017 – Working Group meeting. Notes from meeting available on CPC website.

Winter 2017 CPC Newsletter – Update to residents. Further call for more members to join the Working Group.

27 February 18 – Working Group meeting with ONeill Homer consultants in attendance. Notes from meeting available on CPC website.

12 March 18 – Invitation via Facebook for residents and stakeholders to join a CNP meeting on 22 March 2018.

Spring 18 edition of the Crowthorne Eye – distributed to every household in Crowthorne providing an update on Neighbourhood Plan and inviting participation in the working group to help shape development in the village.

22 March 18 – Public meeting held to encourage more resident involvement. Six task groups identified (Design and Character; Retail; Green Infrastructure; Community Facilities; Employment; Infrastructure). Notes from meeting available on CPC website.

Summer 2018 CPC Newsletter – Update to residents. Call to residents to join the different task groups.

Summer 2018 – CPC nominates various buildings within the Neighbourhood area for local listing.

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Winter 2018 – ONeill Homer prepare first draft pre-submission Neighbourhood Plan for consideration by Working Group and Crowthorne Parish Council.

29 January 19 – Working Group meeting. Notes from meeting available on CPC website.

4 February 19 – Online Facebook launch of the Regulation 14 pre-submission consultation for CNP – reached 2332 people.

Spring 19 edition of the Crowthorne Eye - distributed to every household in Crowthorne, containing details of the Regulation 14 consultation and a paper copy feedback form on the draft pre-submission plan.

4 February – 20 March 19 – Public 6-week consultation on the draft Pre-submission Plan. As well as hard copies being available at strategic locations around the village, two public exhibitions were held at the Morgan Centre on Tuesday 5 March 2019 (attended by 25 members of the public) and Saturday 16 March 2019 (attended by 15 members of the public). The exhibition materials (see Appendix A) were also displayed and feedback forms available at the Annual Parish Meeting (attended by 50 people) held on 19 March 2019. The draft plan was also available online through CPC website.

March/April 2019 – feedback analysed.

7 May 2019 – Working Group meeting scheduled with ONeill Homer to analyse feedback received and ascertain what changes to be made to the NP.

May 2019 – All written feedback from Regulation 14 process uploaded to Crowthorne Parish Council’s website for the public to view. Hard copies available from CPC Parish Office.

June 2019 – Proposed Submission CNP and supporting evidence considered and adopted by CPC.

Regular updates were also provided at the monthly Crowthorne Parish Council meetings and ad hoc Major Development Planning Committee meetings to which the public attend and include a 15 minute public question time. No concerns or issues with the CNP were raised by members of the public at these meetings.

All notes from meetings and any presentations uploaded to CPC website http://www.crowthornepc.org.uk/neighbourhood-plan.html.

A selection of the news, updates, information and public engagement with the CNP process are contained at Appendix A.

1.8 The CNP process began following a residents’ satisfaction survey conducted by Wellington College in 2016. The key themes which emerged identified various areas within the parish which locals felt could be improved, including; the High Street, parking, overdevelopment and policing.

1.9 Further to this CPC applied to BFC to designate the boundary of Crowthorne Parish as the Neighbourhood Area, which was granted on 15 June 2016.

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1.10 Crowthorne Parish Council formed the CNP working group and recruited residents and members of local groups. Work was also undertaken in 2016 to study Locality publications and Neighbourhood Planning legislation.

1.11 A comprehensive briefing on CNP was given at a Wokingham Without Parish Council and CPC Liaison Committee meeting on 27 September 2016, outlining the steps taken to date and next steps. The same briefing update was shared with CPC Councillors and the general public at the CPC monthly meeting in October 2016.

1.12 An ideas meeting, attended by the working group and members of the public, was held in October 2017; attendees discussed the CNP scope. The main themes that emerged as areas of concern for residents and stakeholders included:-

• Lack of parking • Insufficient doctors and healthcare facilities • Inappropriate infill development • Increased traffic • Inadequate bus service • The train station is located in the wrong place • Too many care homes springing up • Ensuring the High Street is accessible to all • Effects of new development on the environment • Loss of employment space at Wellington Business Park to residential

use through permitted development rights.

1.13 An informal consultation exercise in March 2018 and public meeting at Crowthorne Baptist Church tested the proposed scope of the plan. Input from the event showed that the CNP working group were focusing their efforts on the correct areas with great emphasis on green infrastructure, wildlife and the protection of gaps between settlements. See section 4.2 of the Submission Plan for details of the community consultation feedback.

Stakeholder consultations

1.14 Throughout the process, the CNP working group sought to work closely with key stakeholders including the BFC as the LPA.

1.15 Other consultees that the Working Group engaged with included:-

• CVAG (Crowthorne Village Action Group) • Local landowners, including:

o Broadmoor Hospital – West London Mental Health Trust o Royal Military Academy – Sandhurst o Wellington College - Crowthorne

Engaging with hard to reach groups

1.16 There were no specific groups that were felt to be under-represented throughout the process. CVAG has representatives of all demographics within the NP area

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within their membership and CVAG itself had designated representatives on the NP working group. This ensured that the views of the wider population were well represented.

1.17 Crowthorne Village also has a very active Facebook group (We Love Crowthorne

Village) with a wide spectrum of ages and backgrounds represented and membership totalling 15,645. When planning matters or infrastructure issues were debated on this forum the views were noted by the CNP working group and Parish Council officers and members who fed this public input directly back into the neighbourhood planning process. Recurrent themes discussed by the public on the community Facebook page include housing development, parking, a desire for a wider selection of shops and restaurants, improved public transport, a perceived over-supply of retirement and nursing homes, the importance of green infrastructure, air quality/the environment and the need for adequate community facilities/amenities such as GP surgeries. Notably, the online input has mirrored that captured by the earlier Wellington College survey and the public ideas meetings, which reassured the working group that they were on the right track with the areas the CNP needed to address.

Summary

1.18 The CNP has been prepared after considerable community involvement and engagement. The CNP working group has endeavoured to capture and reflect the views of the community for well-designed development to address local needs, along with the provision of community infrastructure.

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2 KEY THEMES FROM CONSULTATION 2.1 Key themes raised at the March 2018 public consultation event, drew out the

following areas of concern:-

• The need for wildlife/cycle corridors • Protection of local forests and woodland • Maintaining strategic gaps between Crowthorne and other settlements • The need for more parking • Enriched retail environment – greater diversity or shops/restaurants • Improved visual appearance of the high Street • Provision of adequate infrastructure for new developments – Doctors,

schools, parks, Post Office, community hub facilities • Provision of affordable housing • Over-supply of care homes • Better public transport.

This Community consultation input, which reiterated the earlier findings of the Wellington College resident’s survey, and feedback which was captured when local planning and infrastructure issues were discussed by those attending the public meetings and in online Crowthorne community forums, informed the pre-submission consultation.

2.2 The working group ensured that the public’s concerns were, where possible, incorporated into the CNP and included polices, as appropriate, to address the concerns: -

• Wildlife/cycle corridors – Existing green infrastructure is very important. The CNP working group sought to include policy that protects the green infrastructure assets of the parish, including promoting its biodiversity assets. The plan therefore included policies CR12 and CR13 to address these important matters.

• Protection of our forests, woodlands and parks – many people cited the green leafy feel as the reason they choose to live in Crowthorne. Policies CR12 and CR13 have been included to reflect the importance to residents of protecting the local forests, woodlands and play parks and how they enhance the visual characteristics and biodiversity within the parish. Design policies also include this to be protected, see specifically CR1.

• Maintaining strategic gaps between Crowthorne and its borders with Bracknell and Sandhurst The neighbourhood plan can only deal with non-strategic matters and issues inside of the designated neighbourhood area. Where it has been possible to protect important gaps inside the designated area, this has been attempted (see Policy CR8). Where it has not been possible to respond through the neighbourhood plan in its policies, the Parish Council has listed matters in Section 6 of the plan to provide a full picture of how the Parish Council intends to deal with the matter.

• Parking – more needed both residential and for shoppers/workers.

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Some of the stated desires of the public unfortunately conflict with others. Whereas some of the individuals and groups who have fed back on both the CNP Regulation 14 consultation, commented in person or online on social media express a need for more car parking in the neighbourhood area. Others raised ongoing concerns about air quality (contributed to by vehicle emissions) in the village and the need to protect the green infrastructure and biodiversity. It has not been possible to incorporate the provision of more car parking in the village into any of the policies in the CNP, however, the need for this improvement to infrastructure has been included in Section 6 – Local Infrastructure Improvements. Parking provision is always considered by the Parish Council when it is asked to comment on planning applications within the Parish, and Council is always mindful of the need for plans to comply with the Bracknell Forest Parking Supplementary Planning Document. The plan focusses on air quality in its policies relating to the High Street.

• Enriched retail environment – more diversity of shops/restaurants and the visual appearance of the High Street. The inclusion of policy CR9 reflects the stated desires of the community to enrich and preserve the visual appearance of the High Street. It is not possible to force vacant shop units to be let or sold to certain types of retail or food outlets, however, the Parish Council is always mindful when considering its comments on any applications for change of use; seeking, wherever possible, to encourage a wide range of shops, restaurants and outlets on the High Street. Ultimately, though, the decision on such planning applications rest with BFC who are bound to apply national and local planning policies in arriving at a decision.

• Provision of associated infrastructure for new developments - such as doctors’ surgeries’, schools, parks/SANGs, roads, Post Offices, Community Hub spaces. New tranches of land are not allocated for development with this Neighbourhood Plan. The Plan is therefore heavily focused on ensuring high quality deign of smaller scale infill building which would not normally bring with it associated infrastructure demands. Additional information regarding Buckler’s Park SANG land, included in the development of the Transport Research Laboratory site has been provided and is included in the Submission Plan in Section 2. Policies CR8 and CR1 CR 8 focus on the need to ensure wooded landscape buffers. On Buckler’s Park this is largely provided by the SANG which sweeps around the edges of the development. Infrastructure plans for Bucklers’ Park and Cricket Field Grove, including the provision of school places, parks, SANGs, roads and Community Hub, are already provided for in existing plans approved by BFC which the developers are required to deliver pursuant to S.106/CIL. The Parish Council has also identified aspirational schemes at section 6 of the Plan to seek to deliver further improvements in local infrastructure which are within its powers to provide for consideration as and when budgetary provisions allow.

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• Provision of affordable housing – large scale developments bring with them the obligation on developers to deliver affordable housing. As the CNP does not allocate any sites it relies on existing policy for affordable housing.

• Over-supply of care homes – there is a perception that there is an over-supply of care homes and retirement properties. There has been a recent surge in development of retirement/senior living property in Crowthorne, adding to existing similar housing stock. Additionally, further plans have been approved for a care home on Buckler’s Park. A considerable proportion of the recent new build retirement living properties in the village remain unsold. It is likely therefore that, driven by the weak demand for such housing in recent times, this perceived problem with over-supply will be self-limiting as developers will not seek to build or change the use of properties which they are unable to sell. As the CNP does not allocate any sites it relies on existing policy for care home provision.

• Better public transport, which is more frequent, affordable and is on the routes people need – e.g. a bus route from the village to the station which is on the outer edge of the village is highly sought after. It is understood that local bus companies will not provide routes which are commercially unviable. The local bus companies have been asked to consider such a route from the village to the bus station but have not agreed or instigated such a service. It is hoped that with the potential increase in residents on Buckler’s Park requiring train commuting services that such a scheme may become viable in the future. The Parish Council has also included a possible scheme at Section 6 of the Plan to consider a mini-bus service funded/subsidised by developer contributions should funding be available for such a scheme in the future.

2.3 In summary, the CNP seeks to address the community’s main concerns and where it has not been able to do so in planning policies the Parish Council has committed to working with other providers to address the remaining matters.

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3 REGULATION 14 PRE-SUBMISSION CONSULTATION

3.1 The CNP working group finalised the draft pre-submission CNP in January 2019. The Regulation 14 Pre-Submission Consultation ran for a six week period from 4 February 2019 until 20 March 2019. A co-ordinated publicity campaign was undertaken which comprised:-

• A notice and the plan were added to the Crowthorne Parish Council

Neighbourhood Plan website area: - http://www.crowthornepc.org.uk/neighbourhood-plan.html

• Notifications were sent to statutory and non-statutory consultees via email (where possible) or hard copy letter if no email address was available. (see below).

• A public notice was put up on the notice boards around the parish. This is shown in Appendix C.

• Hard copy folders containing the Pre-Submission plan and feedback forms were distributed to various local establishments (Parish Council Office, pubs, cafes, Wellington College and the library).

• Two public consultation drop in events with exhibition materials were arranged and publicised.

• A further opportunity for the public to view the exhibition materials and Pre-Submission plans took place at the Annual Parish Assembly.

• Social media was used via Facebook to invite the wider public to feedback their views on the Pre-Submission CNP.

• A hard copy of the Regulation 14 notice and feedback form, inviting all those living and working locally to read and comment on the Pre-Submission Plan, was included in the Crowthorne Eye Community magazine that is distributed quarterly to every household in the village.

Distribution to Statutory and Non-Statutory Consultees

3.2 In accordance with the requirements of the Neighbourhood Planning Regulations, relevant statutory consultees were written to. In addition, a range of parties that the CNP Working Group considered were likely to have an interest in the plan were also written to. All parties were invited to download a copy of the plan and were advised that that hard copies could be issued on request.

3.3 The full list of statutory consultees, which includes the Schedule 1 bodies set out

in the regulations, that were written to is as follows:

Homes and Communities Agency Natural England The Environment Agency English Heritage Historic England Network Rail Infrastructure Company

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Highways Agency Electronic Communications: T-Mobile Hutchison 3G O2 Orange Vodaphone Cable and Wireless Vtesse Networks Ltd Virgin Media Berkshire Fire and Rescue Service South Central Ambulance Service Thames Valley Police East Berks Clinical Commissioning Group NHS Commissioning Board Primary Care Trust West London Mental Health Trust (Broadmoor Hospital) National Institute for Health and Clinical Excellence National Grid Southern Communications Centre National Grid Gas National Grid Properties Southern Electric/Southern Energy Scottish and Southern Energy British Gas Thames Water Utilities South East Water Forestry Commission ( Local landowner) Royal Military Academy Sandhurst ( Local landowner) Crown Estates ( Local landowner) SILVA formerly Bracknell Forest Homes (social housing) Involve - coordinator of local voluntary groups and services Bracknell Town Council Binfield Parish Council Warfield Parish Council Sandhurst Town Council Winkfield Parish Council Hurst Parish Council Wokingham Town Council Wokingham Without Finchampstead Parish Council Old Windsor Parish Council Sunninghill and Ascot Parish Council Sunningdale Parish Council Blackwater & Hawley Town Council Surrey Heath Borough Council

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Rushmoor Borough Council Hart District Council Surrey County Council Hampshire County Council Royal Borough of Windsor and Maidenhead - RBWM Spelthorne Surrey Heath Waverley Council West Berkshire Reading Borough Council Wokingham Borough Council Andrew Hunter Bracknell Forest Council Max Baker Bracknell Forest Council Simon Cridland Bracknell Forest Council Stephen Chown Bracknell Forest Council Bracknell & Ascot Clinical Commissioning Group L & G Homes (Developer and landowner) Barratt Homes (Developer and landowner) BBOWT (Berkshire Buckinghamshire and Oxon Wildlife Trust) Berkshire Conservation Volunteers CPRE Biodiversity Bracknell STOP hate UK - Racial interest group Crowthorne CAB Crowthorne Traders Thames Valley Chamber of Commerce/Trade Bracknell Crowthorne Stroke and Disabled Club Wellington College Crowthorne C of E School Wildmoor Heath School Edgbarrow School/Corvus Trust Eagle House School Churches Together Crowthorne (CTC) St. John's Church Crowthorne Methodist Church Crowthorne Baptist Church Vineyard Church

3.4 A copy of the email sent to the statutory bodies is shown below in Appendix C.

Responses 3.5 In total there were 19 respondents to the Pre-Submission Consultation. This

reflected a mixture of landowners and other stakeholders as well as local residents.

3.6 The table below summarises the responses received to the Regulation 14 consultation.

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Regulation 14 responses

Response Number. Who From Comment

Action Taken.

1 Conservancy Office South East England Forestry Commission,

Advice on Forestry Commission approach and summary of policies

None needed

2 Crowthorne Village Action Group.

Various corrections to document.

Corrections made

3 Campaign to Protect Rural England.

Minor corrections suggested and general approval of plan.

Corrections made

4 Resident Comment Parking, Air Quality and Zebra Crossing on Church Street.

5 Highways England. No Comment

6 Historic England. More information on Conservation Area.

7 Legal & General Homes.

Support Vision & Objectives. Note TRL also now known as Buckler's Park.

Changes made.

8 Resident Comment Reduction of High Street Traffic and over supply of Care Homes.

9 National Grid. No Comment

10 Natural England. Net Gain in Biodiversity to be included.

Plan revised

11 Environmental Agency.

No Comment

12 Sunningdale Parish Council.

No Comment

13 Wellington College. Recognition as Major employer, CR6, CR12 and CR13 wording.

Plan revised

14 Bracknell - Thames Water - Pre-Submission Plan

Need for Policy on Water and Wastewater Infrastructure

Within BFBC Local Plan.

15 BFC response to the Pre-Submission Neighbourhood Plan.

13 Technical Comments plus 25 pages of misc. comments

Some included in Submission Plan

16 Resident Comment Dates Missing, Church and Lych Gate listed, Air Quality

Changes made.

17 Wokingham Without Parish Council.

Various minor changes to wording.

Some changes made.

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18 Bracknell Town Council.

Support for Policies CR1 to 8 and both Cr12 and CR13.

19 Resident Comment Various minor comments Most comments incorporated in Submission Plan.

Responses from statutory consultees, developers/landowners and other interested organisations

3.7 A summary of the key representations made by statutory consultees, developers/landowners and other interested organisations in relation to the extent that the CNP meets the Basic Conditions and any changes made to the CNP as a result of this input are summarised in the Regulation 14 Report prepared by ONeill Homer and dated May 2019 and contained at Appendix C.

Responses from local residents

3.8 Only 3 written comments were received from local residents which were minor comments only. Other input from local residents was captured orally at the public exhibitions. Their input/comments received echoed those public views/input already outlined at section 2 of this statement. Where appropriate, the changes they suggested were made.

Regulation 14 report and changes to the Crowthorne Neighbourhood Plan

3.9 The Regulation 14 report demonstrates the changes that were made to the CNP, to accommodate the consultation responses and input, where appropriate. In essence, only minor modifications were considered necessary to improve the clarity and application of policy wording.

The modifications to policies are summarised below:

CR1 – Amending wording to clarify its application, addition of emphasis on tree protection.

CR2-CR8 – Amending wording to clarify its application. In addition, highlighting the protection of the strategic gap.

CR9-CR11 – Amending wording to clarify its application.

CR12 – Amendments to reflect BFC comments and provision of Green Infrastructure Plan.

CR13 – Amendments to wording to clarify its application and inclusion of Biodiversity Report.

No adverse comments were received in relation to the policies of the plan and the above outlines how the Working Group has responded, where it has been possible, to the helpful comments received.

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APPENDIX A - EXAMPLES OF PUBLICITY MATERIAL USED TO PROMOTE ENGAGEMENT EVENTS Article from Crowthorne Parish Council Newsletter – Summer 2017

October 2017 Crowthorne Parish Council Facebook post

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Article from Crowthorne Parish Council Newsletter – Winter 2017

Extract of article in the Crowthorne Eye magazine for Spring 2018

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Facebook post 12 March 2018

Article from Crowthorne Parish Council Newsletter Summer 2018

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4 February 2019 – Facebook post to Crowthorne Parish Council and shared to local Facebook groups including We Love Crowthorne Village announcing the launch of the Regulation 14 Consultation – post reached 2332 locals

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Extract from Crowthorne Eye Community Magazine Spring 2019 including paper Regulation 14 consultation information and feedback form distributed to every home in the CNP area and all homes and properties in the wider Crowthorne village area.

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Paper comment form included in the Crowthorne Eye Spring 2019 edition.

5 March 2019 – Facebook post to Crowthorne Parish Council and shared to local Facebook groups including We Love Crowthorne Village promoting attendance at the public consultation event on the Crowthorne Neighbourhood Plan that evening for Regulation 14 Consultation – post reached 1670 locals

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5 March 2019 – Facebook post to Crowthorne Parish Council and shared to local Facebook groups including We Love Crowthorne Village promoting attendance at the public consultation event on the Crowthorne Neighbourhood Plan on 5 March for Regulation 14 Consultation – post reached 1670 locals

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15 March 2019 – Facebook post to Crowthorne Parish Council and shared to local Facebook groups including We Love Crowthorne Village promoting attendance at the public consultation event on the Crowthorne Neighbourhood Plan on 16 March for Regulation 14 Consultation – post reached 2501 locals

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Photographs of the consultation material on display at the Crowthorne Neighbourhood Plan’s Regulation 14 public consultation events at the Morgan Centre on 5, 16 and 19 March 2019

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APPENDIX B - PUBLIC NOTICE AND TEXT OF LETTER/EMAIL SENT TO SATUTORY BODIES AND OTHER INTERESTED PARTIES REGARDING PRE-SUBMISSION CONSULTATION

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APPENDIX C - REGULATION 14 REPORT OF ONEILL HOMER DATED MAY 2019 SUMMARISING COMMENTS AND RESPONSES TO PRE-SUBMISSION CNP CONSULTATION FROM STATUTORY CONSULTEES, DEVELOPERS/LANDOWNERS AND OTHER INTERESTED ORGANISATIONS. Report commences on next page.

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oneill homer CROWTHORNE NEIGHBOURHOOD PLAN REGULATION 14 REPORT: MAY 2019 Purpose 1. The purpose of this report is to summarise the outcome of the consultation period on the Pre-Submission Crowthorne Neighbourhood Plan held from 4 February 2019 – 20 March 2019. The report reviews the representations made by some of the statutory consultees, by developers/landowners and the few responses received from the local community. It then makes recommendations for minor modifications to the Plan for its submission. 2. The report will be published by the ‘qualifying body’, Crowthorne Parish Council, and it will be appended to the Consultation Statement that will accompany the submitted Plan in due course, in line with the Neighbourhood Planning (General) Regulations 2012. Consultation Analysis & Recommendations 3. The first section of the report summarises those representations made by statutory consultees, developers/landowners and other interested organisations in relation to the extent that the plan meets the Basic Conditions. The report then summarises comments received from the community. Minor editing and clarification will be dealt with separately as a matter of course. The report does not comment on representations received in relation to amendments to the Crowthorne Design Guide, AECOM September 2018. Details of the full representations made are available on the neighbourhood plan website. 4. During the consultation period, representations were made by Bracknell Forest Council (the Local Planning Authority), Historic England, Natural England, the Environment Agency, Thames Water, the Forestry Commission, Highways England, National Grid, Legal and General Homes, Wellington College, Crowthorne Village Action Group, Wokingham Without Parish Council, Bracknell Town Council, and the Campaign to Protect Rural England. 5. The Environment Agency, Forestry Commission, Highways England and Sunningdale Parish Council had no specific comments to make on the content or policies of the plan. 6. The National Grid confirmed that the high voltage overhead powerline in the Neighbourhood Area boundary is not an issue with regards to any of the neighbourhood plan policies. 7. Bracknell Town Neighbourhood Plan Steering Group supported the Neighbourhood Plan in its policies relating to design, connectivity, green infrastructure and biodiversity.

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8. The Local Planning Authority, Bracknell Forest Council (BFC), has provided formal comments and has confirmed that its covering letter summarises a list of comments provided in relation to the Plan meetings the basic conditions. Some of these are responded to in the supplementary comments section as these are not necessarily directly related to policies. 9. The summary analysis of the remaining representations is provided in respect of each policy below, together with recommendations on making modifications for the final version of the Plan: CR1 – CR8 Design Policies 10. BFC raised concerns that the design policies will constrain development, be difficult to use due to ambiguity, and will not necessarily achieve development that is appropriate to its immediate surroundings. 11. The intention of these policies is not to require every proposal to adhere to every principle. The policy draws a series of attributes from the Design Guide produced by AECOM that demonstrate each Character Areas key features. Therefore, it does not require full adherence to every attribute, but does require planning applications to demonstrate that, where relevant to the location of the proposal, attention has been paid to those attributes in its design. This also allows for a modern architectural response to the vernacular. It is therefore recommended that the policy wording is amended to reflect this. 12. Historic England makes a number of helpful comments and recommends that policies CR1 and CR3 include reference to the Conservation Area and its appraisal and minor amendments to policy clauses in policies CR3, CR4 and CR5. It is normal practice for the Conservation Area to be a ‘character area’ in its own right in character studies and it is therefore recommended that these amendments are made. 13. The Crowthorne Village Action Group (CVAG) suggests a number of helpful non-material amendments and these can be made as a matter of course where possible. The CVAG also specifically comment on Policy CR7 and requests that listing designations are included in the policy, as well as recognition that the Broadmoor Hospital Registered Park and Gardens Grade II have been included on Historic England’s At-Risk Register. The entirety of the Character Area falls within the Registered Park and Gardens designation and national and local policy already ensures protection of designated heritage assets. As the purpose of the policy is to draw attention to its importance in managing design of proposals, it is recommended that the information is included in the supporting text of the policy. 14. Wokingham Without Parish Council requests that the design principles in policies CR2 and CR3 are mutually agreed as it is considered that these character areas extend into Wokingham Without Parish Council and therefore to avoid any conflicting matters in its production of a Neighbourhood Plan. The Design Guide did not assess any areas in Wokingham Without, and Neighbourhood Plans only apply in the designated neighbourhood area. It is therefore recommended that the supporting text clarifies this. With regards to the attributes that have been identified in Policies CR2 and CR3 as set out in the Crowthorne Design Guide, it is recommended that Wokingham Without and Crowthorne Steering Groups discuss and agree final wording of the policies for the Submission Plan.

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15. Legal and General consider recognition of taller buildings is necessary in Policy CR1. The attributes set out in Policy CR1 provides a local context where characteristically (typically) buildings are one or two storeys in height. The policy does not prevent proposals for taller buildings to come forward but requires such proposals to demonstrate how guidance has been applied to ensure that such proposals positively contribute to the character of the parish. See paragraph 11 above for a policy amendment response that, it is considered, would resolve this matter. 16. Additionally, Legal and General comment on the design principle of Policy CR8 in pine cladding being difficult to maintain from a resident’s perspective and it does not weather well. The Design Statement was prepared at a time when the site was being cleared for development and as such no positive aspects from the development scheme, now being built, was recognised in the final Design Statement. This can be made clear in the supporting text of the policy. Additionally, the development, now known as Buckler’s Park, has agreed its own design code with the Local Planning Authority. It is therefore recommended that the supporting text in the policy recognises this. 17. Wellington College recognises that the Wellington College/Edgbarrow School Character Area is the largest and most diverse and that not all development proposals will apply for each proposal and therefore requests that where applicable is included in Policy CR6. See paragraph 11 above for a policy amendment response, that it is considered, would resolve this matter. CR9 Crowthorne Centre and CR10 Station Parade, Duke’s Ride 18. BFC recommends that the policies are merged with the design policies for the character area in which these shops and businesses fall and suggests that the policy attempts to change the retail hierarchy designations. It is also suggested that the policies need to be amended to clarify a number of matters raised in detail, although these are not defined as basic conditions issues in the covering letter, these matters have been considered and amendments will be made in the Submission Plan where considered necessary. 19. As there was a need to write a separate policy on Crowthorne Centre and Station Parade, Duke’s Ride it was considered that it would be clearer if positive attributes for design purposes were highlighted in the same policy. Planning Practice Guidance1

states that the reasoning and evidence informing the Local Plan process is likely to be relevant to the consideration of the basic conditions against which a neighbourhood plan is tested. With the updated Western Berkshire Retail and Commercial Leisure Assessment 2016 being produced, the limited weight that can be given to the Local Plan 2002 due to its adoption prior to the 2012 National Planning Policy Framework (NPPF), and the revised NPPF 2019 allowing any policy, not simply strategic policies/local plans, to define the hierarchy of town centres (§85), it is considered that it is possible for the Neighbourhood Plan to establish the designation of Crowthorne High Street and Station Parade, Duke’s Ride. It is therefore recommended that no changes are made. 1 PPG 009 Ref ID 41-009-20160211 CR11 Employment

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20. BFC highlights that Wellington Business Park is not currently a defined employment area. The emerging Draft Local Plan recognises that Wellington Business Park plays an employment role in the Borough and as its existing development plan recognises the harm that the loss of small businesses leads to and indicates that it will be included as a defined employment area. With BFC not including this area in its nominations for Article 4 directions, Wellington Business Park continues to be at risk from permitted development without any consideration or tests that can be undertaken during a planning application process. The Neighbourhood Plan defining it as an employment area will not prevent permitted development rights, but its absence from the Neighbourhood Plan will be conspicuous. It is therefore considered that the policy should continue to include Wellington Business Park, however, the policy should be amended to make it clear that the Neighbourhood Plan is defining Wellington Park as an employment area. This is informed by the reasoning and evidence base of the emerging Local Plan (see footnote 1). CR12 Green Infrastructure 21. BFC is concerned that the policy promotes links to the Thames Basin Heath SPA and makes a number of suggested amendments. It also offers its services in creating a Green Infrastructure Network map. It is recommended that the suggested amendments are made and that the Steering Group engages with BFC to create a Green Infrastructure Network map as it already holds this information. 22. The Campaign to Protect Rural England (CPRE) Berkshire Branch is supportive of the neighbourhood plan in terms of the process it has followed in its relationship with the emerging draft Bracknell Forest Local Plan and in accommodating the community’s views. It recommends that policy reflects the importance of green spaces/infrastructure in and adjacent to the parish, due to the sever constraints that the Thames Basin Heaths SPA places on access to the countryside and the threat of the human footprint to this SPA. Wellington College also comments on the policy intent and seeks a distinction from the different green infrastructure assets as some of the assets identified are private and not accessible to the public. The amendments recommended by BFC should sufficiently address these concerns. 23. The CVAG recommend that strategic gaps should be included in the Green Infrastructure Network as these are considered valuable wildlife corridors. The accompanying note sets out recommendations in relation to gaps, including proposed amendments to Policy CR8 to include reference to the TRL ‘landscape buffer’ and the 500-metre strategic gap between the TRL site and the built-up area boundary of Bracknell. CR13 Biodiversity 24. BFC is generally supportive of the policy but makes some suggestions to amend the policy wording and suggests that there is an opportunity to further define local biodiversity assets. The Steering Group should provide O’Neill Homer with any information held on local biodiversity assets, Berkshire Wildlife Trust and/or the Thames Valley Environmental Records Centre may be able to provide additional information. It is not considered inappropriate to quote the nationally and internationally designated sites within the policy to demonstrate the high environmental quality of the designated neighbourhood area. Additionally, the policy cannot be amended to influence anything outside of its designated boundary. It is therefore recommended that only minor policy amendments are made as suggested in BFC’s response.

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25. Although Natural England has not commented on specific biodiversity policies and objectives of the plan and has referenced the 2012 NPPF in some parts of its response, it is possible to recommend amendments based on the advice given. The plan already contains an objective to maintain and enhance the quality and abundance of environmental assets, which includes biodiversity (and heritage assets as noted by Historic England). Both Policies CR12 and CR13 promote a biodiversity net gain and connectivity with a net gain being a specific requirement in Policy CR13. As these matters have already been included in the objectives and policies of the plan it is not considered necessary to make any amendments with regards to a net gain in biodiversity and connectivity. 26. Wellington College on the other hand suggest that the policy should not require a net gain in biodiversity but that this should only be encouraged. The NPPF published in 2012 required biodiversity net gains ‘where possible’ at paragraph 109. The revised version published in 2018 and then again in 2019 removes the wording ‘where possible’ at paragraph 170d) demonstrating the government’s commitment to ensure habitats are protected and enhanced for the future. In light of this and the advice received from Natural England it is not considered necessary to make any amendments with regards to a net gain in biodiversity. Other Comments & Analysis 27. BFC suggests that the boundary for the Broadmoor employment area is incorrect and that the Policies Maps in general are not clear. It is recommended that the Policies Maps are amended as requested to avoid ambiguity. 28. BFC also suggest that the plan period should be amended to bring it in line with the expected plan period of the emerging Local Plan. As the original intention was to align the Neighbourhood Plan with the plan period of the emerging Local Plan it is recommended that the plan period is amended to 2018 – 2036. 29. BFC also raises matters surrounding a link between objectives and policies, including a glossary in the plan, removing some design matters from the design policies such as trees and important views, and including a separate monitoring section in the plan. It is recommended that a section regarding monitoring is included in the plan, as set out below: Monitoring The Crowthorne Neighbourhood Plan will be monitored by BFC using data collected in planning monitoring reports. The neighbourhood plan policies will form the core of monitoring activity, but other data collected and reported at a local time relevant to the Plan may also be included. 30. No other statutory consultees or members of the community commented that the plan was not easy to read and indeed this template has been used by a large amount of Neighbourhood Plans which have passed examination. However, in the interests of an ongoing good working relationship with BFC it is recommended that the objectives are linked to each policy. The Steering Group should consider if it wishes to produce a glossary and provide O’Neill Homer with a copy to include in the Submission Plan. 31. The NPPF requires planning policies to ensure that developments ‘are visually attractive as a result of good architecture, layout and appropriate and effective landscaping’ and ‘are sympathetic to local character and history, including the

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surrounding built environment and landscape setting’ (paragraph 127). Additionally, the existing development plan requires the enhancement of landscape and the promotion of biodiversity, (CS7: Design) and the emerging Bracknell Forest Local Plan includes a specific clause on the retention and enhancement of existing trees in its Design Policy (LP18). The plan is design-led, and trees and views, form part of the local character and history. It is therefore not considered necessary to separate these elements from its design policies, however additional protection for existing trees and hedgerows could be sought in Policy CR1. It is therefore recommended that Policy CR1 is amended. 33. Natural England also suggested that the Neighbourhood Plan mentions favouring developing brownfield sites over greenfield sites, provided the brownfield sites are not of high environmental value. These provisions are already set out paragraph 117 and footnote 44 of the NPPF. It is therefore recommended that no changes are necessary. 34. Natural England also provide guidance on Strategic Environmental Assessment and Habitat Regulation Assessment; however, it had recently been consulted on a screening opinion by Bracknell Forest Council in which it confirmed that it agreed that the Neighbourhood Plan does not require these assessments. 35. BFC (on page 28 of their response), CVAG (on pages 4 and 5 of their response), CPRE (on page 2 of their response), and Legal and General (on page 3 of their response, have made some comments regarding minor amendments necessary to the Crowthorne Design Statement 2018 produced by AECOM. None of these comments will impact on the plan in meeting its basic conditions, however as a matter of accuracy the Steering Group should confirm whether these amendments will be made so it can be reflected in the Submission Plan if necessary. 36. Wokingham Without Parish Council and CVAG have suggested that a list of non-planning matters is included in the plan. This will not impact on the plan in meeting its basic conditions. The Steering Group should provide O’Neill Homer with a list of such projects to include in the Submission Plan if it wishes to do so. O’Neill Homer will include the list identified in the Crowthorne Three Year Strategy Plan 2016 – 2019 as a starting point. 37. Thames Water have suggested that the plan should include a water and waste water policy urging developers to consider the net increase in water and waste water demand to serve their developments but also any impact off site. This neighbourhood plan does not allocate housing development, nonetheless the issue is understood, and the emerging Local Plan will deal with this matter. 38. Wellington College seek recognition that it too is a major employer in the area. Broadmoor Hospital was identified as a major employer in the area in the Core Strategy and it highlights that there is currently an amendment being considered to the boundary of Edgbarrow Woods Local Nature Reserve. This information can be included in the Submission Plan for accuracy. Community Comments Summary 39. No adverse comments were received in relation to the policies of the plan and residents make a number of helpful comments. 40. It was clear that there remains little support for BFC’s Air Quality Action Plan, although there remained support for proposals demonstrating how air quality

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improvements may be made in Policy CR9 with it being considered that this should be a requirement rather than encouraged. Additionally, some infrastructure projects are suggested as a solution to the air quality issue in the High Street such as the introduction of electric charging points, and the addition of a zebra crossing at the end of Church/Waterloo Road to improve connectivity which the Parish Council should note. 41. Comments also include reference to strategic gaps (see paragraph 23 above). 42. There was a request to see the Historic Environment Record data described in 2.2 mapped and included in the plan. Should the Steering Group wish to include this information it should request such mapping from Berkshire Archaeology who manage the Historic Environment Record for this area. This will not impact on the plan meeting its basic conditions. 43. Additional information regarding Buckler’s Park, SANG land included in the development of the Transport Research Laboratory site has been provided and can be included in the Submission Plan in Section 2. 44. Some comments are not able to be accommodated as it is just not possible in planning policy, such as insisting affordable rents for flats. 45. To conclude, no major amendments are necessary to the Plan as a result of community comments. Minor editing and clarification requested will be dealt with as a matter of course separately. Summary 46. Only minor modifications are considered necessary to improve the clarity and application of policy wording. With those modifications made, it is recommended that the Neighbourhood Plan can proceed to submission without further formal consultations.

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47. The modifications include further actions for the Crowthorne Neighbourhood Plan Steering Group as follows: i. Discuss policy wording of CR2 and CR3 with Wokingham Without and advise ii. Engage with BFC to produce a Green Infrastructure Network Map within agreed timetable iii. Request further detail on local biodiversity assets from Berkshire Wildlife Trust and/or the Thames Valley Environmental Records Centre iv. Produce a glossary for the Plan v. Contact AECOM to request response to comments made in Reg 14 consultation and necessary amendments to the Crowthorne Design Guide 2018 (see paragraph 35 above) vi. Provide O’Neill Homer with a list of non-planning matters that have been identified for inclusion in Section 6 of the plan vii. Request Historic Environment mapping for Crowthorne from the Berkshire Archaeology who manage the Historic Environment Record for this area