Why inspectors reject local plans.

In recent years, quite a number of councils’ local plans have been found unsound or in need of main modifications by planning inspectors.  Several councils were said to be too ambitious about plans for a so-called ‘garden village’, and as we know WBC’s local plan relies on a ‘Loddon Valley Garden Village’, a.k.a 4,000 houses to be dumped on Hall Farm between Shinfield and Arborfield. It is due to be sent to the inspectors soon.

            Many residents who have studied it consider the Hall Farm proposal unsuitable for the Shinfield-Arborfield area. Plausible grounds for objecting to the plan include its failure to show convincingly that highway capacity and public transport availability will cope with large-scale development on the site. It does not clearly demonstrate how utilities infrastructure will be in place when required. And its preference for Hall Farm over other sites on sustainability grounds looks questionable, too.

          It’s striking to see the same weaknesses have been picked up by planning inspectors judging other councils’ local plans, and have been cited as reasons for not accepting them.

          If we are finalising our objections to WBC’s local plan, it’s worth looking in some detail at why planning inspectors have rejected or required main modifications of other councils’ plans. 

Questions on highway capacity

Tandridge District Council (Surrey) submitted a local plan involving a ‘garden community’ with around 4,000 dwellings in South Godstone. It was unsound and should be withdrawn, the planning inspector ruled. Modifications would not be enough to make the plan sound. He said there were ‘significant unanswered questions’ concerning highway capacity, particularly after funding for transport infrastructure from the Housing Infrastructure Fund was refused. More work, he said, was needed to ensure local roads weren’t overwhelmed by proposals for a 4,000-home garden community.

Take note: ‘Significant unanswered questions about highway capacity’, and a risk of traffic generated by 4,000 houses ‘overwhelming local roads’. He might almost have been commenting on the Hall Farm proposal.

Similarly, plans by Maidstone Council to create two ‘garden villages’ were judged unsound for reasons of overburdening existing transport facilities in the area. The planning inspector considered a new railway station and better links to the M20 and M2 would be required to justify adopting the 5,000-home Lenham scheme. The new rail station would need to be built to serve the development at an early stage, and the council would need to do additional work to show that off-site improvements required to the M20 Junction 8 would be deliverable.

The proposal for a 2,000-home garden village at Lidsing, on the border of Medway and Maidstone was also found to be ‘not sound’. For it to be made acceptable, the inspector said he would need further evidence that a safe connection could be achieved to a fourth arm of the M2 Junction 4, as well as more detail on other off-site highways measures to mitigate the effects of the development.

Again, a council had proposed a local plan without doing enough to mitigate the impacts on traffic and transport of what they were proposing.

What’s more, the inspector’s report also required Maidstone Council to provide further evidence to show how it would deal with water treatment and quality. This is very much an issue locally too, where the new requirements of WBC’s housing plan would impose massive pressure on financially challenged Thames Water. The company is already struggling to cope, even with current demand on drinking water and waste water treatment.

Will the strategic infrastructure be there?

Another reason for rejection can be that the inspectors question the council’s ability to see its long -term plan carried out satisfactorily. Uttlesford’s (NW Essex) local plan, with a Garden Community approach, was found to ‘predetermine’ the strategy ‘long beyond the plan period’ and was called ‘unduly inflexible’. The inspectors were unconvinced that the mechanisms by which the strategy would be delivered were not readily evident. They were not satisfied the council had provided enough ‘detail and definition on strategic infrastructure requirements and scheme viability testing’.

            Words come easily to councils setting out an inspirational future ‘garden village’ utopia. But convincing planning inspectors that the scheme will be implemented with the infrastructure required is another matter. Uttlesford Council found this out the hard way.

            A similar reason was given for sending back the local plan jointly produced by Colchester, Braintree and Tendring councils in Essex. It featured three ‘garden comunities’. Again, the inspector had doubts about the delivery of the strategic infrastructure these communities required, in particular the rapid transport system routes required. He ruled out two of the three proposals. He also noted that the ‘garden communities’ were strongly opposed by local residents.

            Both points are closely relevant to the Hall Farm development scheme. Planning inspectors can be influenced by a high level of local opposition to the ‘garden village’ proposal. They may well also find fault with its over-ambitious infrastructure requirements.

Unrealistic timescales

Even when the problem wasn’t the ‘garden community’ itself, inspectors found problems with local plans. Havant Borough Council (Hampshire) failed to get approval for its Local Plan in 2021. The Plan was sent back by the Government’s inspector because it had set unrealistically high targets for several housing projects. The inspector referred to a study by Lichfields, entitled ‘Start to Finish’ (2nd Addition, February 2020). This showed sites of 2,000+ dwellings take on average 8.4 years from validation of first application to first completions, including the delivery of necessary infrastructure. Given the difficulties and timescales involved in getting these sites going, the Council’s forecast of first completions in 2026/27 was judged unrealistic. Its completion schedule had not taken into account the time needed to construct a link road first. The inspector concluded: ‘First completions are unlikely to occur until 9-10 years from now… Based on the assumed delivery rate of the Council, this removes 400 dwellings from the Council’s anticipated supply over the Plan period.’

            WBC’s LP forecasts about 500 houses built by 2030. Supposing the first planning permissions were granted soon after inspectors approved the plan next year, that figure looks unrealistic if the Lichfields study of completion timescales is anywhere near correct.

            So will the Hall Farm plan really meet the intended housing target within the plan period, or will there be once again a five-year supply shortage, allowing developers the dreaded free-for-all?

Skewed site comparisons

Finally, there’s the question of how well the local plan convinces the inspectors that alternatives have been duly considered. As happens quite often with plan examinations, the Hart Council (Hampshire) LP was criticised by the inspector for lacking evidence on deliverability of the planned housing. In addition, a further assessment was called for via the Sustainability Appraisal which the inspector said needed to be carried out in an impartial manner considering all possible alternative future strategies, implying that Hart Council’s appraisal wasn’t. He noted ‘a lack of testing to demonstrate the new settlement to be the most appropriate long-term growth strategy’, compared with other options.

            How the comparisons between Hall Farm and other sites were used in Wokingham’s Sustainability Appraisal is likewise open to question. To say the least, the sustainability case for Hall Farm over other sites such as Ashridge Manor and Twyford Gardens does not appear strong when you look at the metrics used in the WBC Sustainability Appraisal.

            So - all in all, WBC’s local plan, with its cuddly-sounding ‘Loddon Valley Garden Village’, is NOT a done deal, and we mustn’t think it is.

            The reasons for objecting to it are reasons why the planning inspectors have sent back other local plans.

            They can do the same with this one.

Pat Phillipps