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Application 24/00091 – Maidenhead Golf Club
Comments on Application 24/00091 – Maidenhead Golf Club Outline application for a residential led development of 1500 homes, primary and secondary schools, a local centre, public open space including landscaping and associated infrastructure, demolition of existing buildings (ex 2 Rushington Avenue). This is the biggest development scheme identified within the Borough Local Plan and is also the most contentious. It is a key element in delivering the targeted housing growth for Maidenhead. Because of the sensitivity of the site it is essential that the proposals reflect a number of factors: The development should not be too high density and should be focussed on delivering family homes rather than flats – which have dominated recent residential development in the town centre.
BUILT ENVIRONMENT AND HOUSING Affordable / social housing in the form of flats is restricted to the northern section. Social mix is improved where such dwellings are dispersed throughout a development scheme. Rather than flats, the southern section along the Green Spine should have high density terraced town-houses or maisonettes with amenity garden space for families. These have been successfully designed and delivered in many locations throughout the UK as an alternative to flats. High density housing can be achieved without the construction of more flats. The proposed larger 3 and 4 bed semi and detached houses should be retained and increased in number. The overly high density of residential development in the western section of the site is a major fault in the proposed application. Housing should be dispersed southwards and eastwards. Sensitive areas of green space should be retained and protected as required and it is important to retain a degree of open public space within the site. However, as it stands the density levels of housing is unbalanced across the scheme. This issue is aggravated by the need to accommodate the two schools. ACCESS AND TRAFFIC MOVEMENT We welcome the decision to restrict through vehicular traffic on the site from north to south, with only buses (controlled by a bus gate) permitted. The provision of parking spaces is not clear, although it is anticipated that the northern section will rely primarily on cycling and walking to access the town centre and railway station. The provision of parking spaces in the southern section is also unclear, but there will be considerable vehicular traffic to the M4, out of town shopping and business parks and local towns. In addition the GP surgery, pharmacist and the local centre will generate two way vehicular traffic As it is anticipated that the majority of Elizabeth Quarter residents will be “incomers” (i.e. not moving within Maidenhead) much of this traffic is incremental – and has to be accommodated on the already overloaded local road network. One of the members of Maidenhead Civic Society Planning Group – Brian Davies - has reviewed the Transport Assessment documents which accompany this application and his detailed comments are attached with this letter. GREEN CREDENTIALS SUMMARY
Martin McNamee Below: - Comments on Transport Assessment Comments on Elizabeth Quarter Transport Assessment for Maidenhead Golf Course January 2024 prepared by motion and submitted as part of the outline planning application. Section 1.6 states that the report demonstrates that the residual impact of the proposed development will not be severe. This is disputed as will become evident. Section 2.1 fails to mention the RBWM Local Transport Plan 2012-2026. In the absence of any revision to this plan, this is assumed to be still current. It also fails to mention the UK Government document “Guidance Travel Plans, Transport Assessments and Statements”. (From: Department for Levelling Up, Housing and Communities and Ministry of Housing, Communities & Local Government, Published 6 March 2014). Section 2.3 quotes selected sections of the NPPF. Section 114 (d) states “it should be ensured that …any significant impacts from the development on the transport network (in terms of capacity and congestion), or on highway safety, can be cost effectively mitigated to an acceptable degree”. This has not been demonstrated. Section 117 of the NPPF states: “All developments that will generate significant amounts of movement should be required to provide a travel plan, and the application should be supported by a transport statement or transport assessment so that the likely impacts of the proposal can be assessed”. Section 2.14 recommends that travel plans should include “benchmark travel data including trip generation databases; and relevant information about existing travel habits in the surrounding area”. There is no evidence that this has been done. The surrounding area is either Maidenhead as a whole, or better still, the area bounded by the railway line, A308(M), A308 and A404(M). The assumptions used for vehicle use are not based on any evidence. Section 2.23 mentions “The exploration of a new vehicular link between Shoppenhangers Road and Braywick Road that would provide an additional access into the site and deliver environmental and public realm improvements to the south of the railway station”. However, no evidence of the conclusion of any such study is provided. The same section also mentions the following, without any conclusions or recommendations:
Section 2.30 (and 7.3) mentions the green spine is providing north -south connectivity. In fact, it only provides connectivity for pedestrians and cyclists, and this will not occur until the later phases of the development are completed, not before 2030 and possibly much later. Section 2.32 states “As the new neighbourhoods emerge there is the opportunity to improve connections in an east west direction around the south of the town as well as new development creating north-south movement to and from the town centre providing better choices of sustainable movement for existing residents as well as offer new residents more convenient options than the car for local journeys”. Is this opportunity part of the outline planning permission and if not, have RBWM set aside any funds for studies regarding this opportunity? Section 2.33 refers to the Harvest Hill corridor. “To integrate the corridor within a new neighbourhood giving it purpose as an East-West route”. This statement needs clarification. Is it not currently an East -West route, and if not, how will the provision of a new entrance to the development and some footpaths make it become an East-West route without other significant enhancements such as widening, street lighting, widening the road for turning lanes at entrances, etc.? It is currently unsuitable for the over 50% increase in traffic predicted by 2033, the figure of 50% being a gross underestimate. Have the other new developments to the south of Harvest Hill Road been taken into account? Section 3.11 states “It is generally accepted that a reasonable journey distance within which walking could replace car trips is 2 kilometres. This is reflected within MfS, which notes that walking can replace short car trips, particularly those under 2 kilometres, a 25-minute walk time”. Provide evidence that “it is generally accepted”. The best evidence is provided by a detailed report produced by Sustrans in 2022 called “Walkable neighbourhoods: Building in the right places to reduce car dependency”. This report decries the lack of consistent walking and cycling length data and gives examples of that used by various councils. Whether a fit person with time on their hands can walk 2km is not the issue. What is important is the distance the population are currently prepared to walk and the increasing average proportion of the elderly in society must also be taken into account, reducing the current estimates still further. The Sustrans report states “When journeys are short enough, most people walk. 800m, or approximately half a mile, is generally considered a standard walkable distance as it typically takes approximately 10 minutes to walk, and a 20-minute walking trip (1,600m total) has been found to be the longest distance a majority of people are willing to walk to meet their daily needs. A separate Government report states that most walking is undertaken for leisure purposes, not for business or other needs. So, most people are prepared to walk 800m if fit and healthy and the weather is not inclement, but the majority of the population draw the line at 1.6km. The figure of 2km as a base case is fanciful and not supported by current data. The Sustrans report says, “The scoring used within a Sustainability Appraisal should be considered carefully, starting with 800m as a maximum acceptable distance, and then determining whether a different threshold or a range is more appropriate”. It should be remembered that Sustrans is a walking and cycling charity, wishing to prioritise walking and cycling! Government cycling statistics for 2023 state: The average person in England in 2022:
The 5km distance used is therefore reasonable, but only when it is used to reflect that just 2% of trips are made by cycle and these should not be made to carry any significant amount of shopping. Figure 3.17 lists local amenities. Larchfield School and Desborough schools are both fully subscribed at present, so will not be used unless considerably expanded. Forest Bridge is a special needs school. Many of these amenities are beyond a reasonable walking distance. Not many residents are going to walk or cycle 2km to do their supermarket shopping. If this is disputed, evidence is required. Section 3.23 mentions the Elizabeth Line as one of a number of transport options which are now more likely to provide a good alternative to the private motor vehicle. The stations served by the Elizabeth Line are as previously served by GWR services, except that transfer to the London Underground network is now easier in many cases. Evidence is required to show that the Elizabeth Line has reduced the need for private transport. Section 4.19 covers parking provision. The RBWM parking space allocation dates back to 2004 (i.e. 20 years ago). It would appear that RBWM have not updated this document and it is quite apparent that it does not reflect current needs. One has only to visit a new development called “The Loftings”, a similar distance (if not closer) to the station and town centre, to see that the parking provision is woefully inadequate with parked vehicles parked across the pavements and footpaths around the apartments as the estate roads are too narrow and parking provision inadequate. If parking is not provided, residents will not go without a vehicle, they will just park on footpaths, making it impossible for mobility scooters, prams, etc, to pass. The parking space allocation urgently needs to be revised, based on how residents actually live, not wishful thinking. In section 5.8, the statement is made that it has been assumed that 80% of primary and 50% of secondary school trips are internalised. This can only be possible if both schools are provided at the onset, they progressively ramp up and expand as demand increases and the schools only cater for residents living in the new development. Section 5.10 mentions a high degree of internalisation for the local centre which presumably operates in the same way. Please confirm that this is the plan, as traffic calculations appear to have been based on this assumption which must be questioned. Section 6.31 states “Based on the above (north and south access figures), it is evident that the two site accesses provide adequate capacity to serve the proposed development and that drivers will be able to re-route in order to minimise congestion and delay”. As there is no link for cars between the two entrances/exits, it is unclear as to how drivers can re-route to minimise congestion. Please elaborate. In summary, there are a number of assumptions which form the basis of the transport calculations which are questionable. Many of these assumptions are either erroneous or lack credibility. The local transport network is at or near capacity as things currently stand, at both morning and evening peaks, and the proposals do not address the fundamental need to significantly upgrade both Harvest Hill Road and Shoppenhangers Road. B J Davies 26.01.24. |