260 houses in Emmer Green - Speak up before 25th September.
Please don’t think that you can’t do anything about it. The Gladman proposal for 245 homes on the north of Emmer Green was successfully fought off. With your help we can do the same! We promised you last week that we would get back to you with a more detailed assessment of the proposed development on Reading golf course. Here it is.
You are welcome to take out of it what you wish. You may even only want to concentrate on one or two aspects. But please remember, do NOT copy and paste. The council will ignore your comment if you do.
Quick Reference
Council Application Number: 200713
Email: planning.comments@reading.gov.uk (include your name & postal address to be considered, as well as the application number)
Letter: Planning Dept, Reading Borough Council, Civic Offices, Bridge Street, Reading, RG1 2LU
Closing Date: 25th September 2020
Link to make an Objection on the Planning Portal - http://planning.reading.gov.uk/fastweb_PL/detail.asp?AltRef=200713 (Frequently Offline, please email instead if it doesn’t work).
This will be first major housing estate in north Reading since Bugs Bottom. This application has inconsistencies, basic arithmetical errors and biased interpretations of data and it is non-compliant with Council policies. Please contact us if you want more details on exactly which policies are contravened.
There are 5 significant errors or unreasonable interpretations of data in the applicant’s plan:
The applicant talks about 485 parking spaces on site. However, they have actually allowed for 592 car parking spaces. It is reasonable to assume that they are expecting that number of cars on the site, yet the plan assumes far less for traffic predictions.
The data models feed into the claim that the impact is negligible. They claim that the 2019 queue length at the Prospect Street/Peppard Road traffic lights is 17 cars in the morning peak hour and would increase to 26 cars (+42%) if the development went ahead. That is NOT negligible.
The applicant uses 2019 data which is unrealistic. Our own observations have shown that the queues are regularly 3 times greater than 17 cars in school holidays, let alone peak!
Their traffic counts were done at a time of roadworks in school holidays.
It also has arithmetical errors (e.g. the applicant claims a 39% impact on Kidmore End Road when, in fact, it is closer to 65%).
Considering the 65% traffic increase on Kidmore End Road, there is already a long stretch of single lane traffic on the approach to Peppard Road, both next to Emmer Green Park (Emmer Green Common – a protected piece of parkland) and next to the White Horse pub. They claim that no road widening required (probably because of the above miscalculations). This is NOT credible.
Kidmore End and Grove Roads are very busy roads with a constant stream of often vulnerable pedestrians and cyclists. Adding many more vehicles will make it more dangerous in terms of accident risk and air pollution.
There will be 20,000 HGV movements over 5 years of construction, plus other site traffic. This will have a very significant impact on the safety of local residents on these two roads and it will certainly result in parents being much more likely to drive their children around the area rather than allowing them to walk or cycle. The only construction access is via Kidmore End Road and Courtenay Drive. These minor residential roads will crack up and need constant repair.
The decreased and inefficient north Reading bus service, lack of bus and cycle lanes means that residents in Emmer Green are largely car-dependant. Government states that the focus for development should be on locations which are sustainable by limiting the need to travel. That is NOT the case here.
The assessment in the plan is limited to a 1km radius of the site but emissions will be felt over a much larger area. The air quality in Caversham already fails to meet statutory targets. Electric cars are not coming fast enough and nearly 600 extra polluting cars will make it worse. It will be particularly dangerous for the children who attend the many local schools and nurseries past which traffic will flow on a regular basis, including Emmer Green Primary, Emmer Green Kindergarten, Emmer Green Pre-school, Highdown School, The Hill Primary School, Queen Anne’s School, Chiltern Nursery and Training College, Caversham Primary School, Hemdean House School, etc.
The assessment uses an inappropriate method of measuring NO2 concentrations. PM2.5 is only measured at Cemetery Junction where NO2 levels are relatively low and therefore PM2.5 is also likely to be low. In Caversham, where NO2 levels are high, it is likely that PM2.5 levels will be much higher also. There are also false claims regarding CO2 emissions from the predicted extra traffic.
The Council recently declared a ‘Climate Emergency’ and set aggressive CO2 targets. Disregarding TPO’s and removing 118 mature trees runs entirely contrary to their need to meet these targets. The applicant plans to plant saplings to mitigate this loss but they will NOT absorb as much CO2 as those removed. This puts the Council’s legal duty to improve air quality “in the shortest possible time”, under the Government’s 2019 Clean Air Strategy, at grave risk.
Providing an empty Health Centre (the ground floor of a block of flats) is different to filling it with doctors, nurses and practitioners. This is notoriously difficult to achieve. No indications have been given how this will become operational, so the building could be empty for a long time. Indeed, our understanding is that the NHS have not to date considered such a new medical facility in Emmer Green.
Since the closure of Priory Avenue and Peppard Road surgeries residents of north Reading have found it increasingly difficult to access healthcare provision with many having to sign up with surgeries in south Reading or even Oxfordshire. This development will certainly increase the strain on north Reading’s already overstretched health care services.
The increase in dust and fumes from the site, coupled with a damaging increase in air pollution from construction traffic and private cars can only have a detrimental effect on the health of local residents, particularly children and the elderly. The demolition pollution has also been incorrectly assessed. Given that the site is within metres of a pre-school and 3 retirement communities at Lyefield Court, Chiltern Court and Fishers Court, and it borders a large primary school, this is of particular concern.
Emmer Green Primary is often oversubscribed and there are families, who live well within the catchment area of the school, who have been unable to send their children to their local school. This results in thousands of unsustainable car trips every year to Sonning Common or Kidmore End to get their children to school. A development of this size will exacerbate this issue and leave many more families unable to access their local catchment school within Reading Borough. Even existing parents in a catchment will be compromised after being edged out by in-fill development.
There is a TPO on all the trees on site and the applicant proposes to remove 118 of them. While the applicant is committing to replace them one for one, there are risks both to new trees and existing mature trees due to their proximity to the proposed housing. This is particularly evident on the sections bordering Gorselands and Lyefield Court where the mature trees are so close to, and in some instances within, the boundaries of some of the small gardens. As a result, they will have a significant overshadowing effect and may in the future be at risk of thinning, cutting back, crown lifting or, in the worst case scenario, being removed altogether.
Risks to the screening effects of the trees on the site are further compounded by the inaccurate estimations of the growth rate of mature planting stock. The estimation is set at 300mm p.a. which is reasonable for young stock but mature stock takes longer to establish and so it will not grow as quickly nor will it reach the suggested 9.2m.
Planting 1,000 trees in Oxfordshire does not meet the objective of increasing tree cover in Reading. Many of them will not survive anyway.
Rare bat species, kite nesting and many other bird habitats are on site, yet the applicant vastly under-estimates the impact on them. The applicant examines trees, ground vegetation, animals, birds and insects, each in isolation, not understanding how they work together in balance. Some are only partly assessed.
The site is dark at night, the main source of light coming from the clubhouse and some from surrounding houses which are mostly screened by mature hedging and trees. With lighting on the streets, paths and open spaces as well as coming from the houses themselves the light levels will have an adverse effect on adjoining houses and will increase light pollution in South Oxfordshire, not to mention the disastrous effect on the local wildlife.
There is no assessment from the Environment Agency or Thames Water. Drainage is poor and flooding risk is under-estimated despite numerous cases of flooding on site. Neither did it consider the removal of 118 mature trees in their assessment of risk.
There will be a significant impact on Emmer Green Primary School and Emmer Green Pre-school, yet the data collected in the plan was during half term holiday. The data is thus not representative.
The Council states that all new developments should respect the size and character of other similar spaces in the vicinity. That is not the case here. Also, some of the buildings will be high. The proposed health centre and flats would be 12.5m high to ridge. There are no other 3-storey buildings in the area. We assert that this development would be wholly out of keeping with the local character.
The site is not in easy walking distance of the Emmer Green shops and the majority of residents will use their car.
While there may not be official public access to the site that does not devalue its landscape quality. It is enjoyed visually and for informal dog walking by a large local community. Even the Deputy Leader of the Council used to walk his dog across the course. This unofficial right of way for local residents has been in place for many years
Much is made of the provision of a large degree of open, public space, but consider this:
The large area of ‘open space’/country park is in South Oxfordshire. It is 800m from the nearest access point to the site off Kidmore End Road, so it is remote from the community it is supposed to serve and no provision has been made for parking for residents to access it.
The applicant has also made submissions to SODC to have this ‘open space’ included in their Local Plan and this shows that the Golf Club has no intention of retaining this land as open space in the long term.
There is no continuous green space within the development. The proposed green space is fragmented by SUDS ponds, roads and housing and there is no green link with the ‘country park’, woodlands and allotments to the north. To access these areas, residents would have to go down the new estate road.
It is not clear who will be managing the green spaces within the development. Although it is proposed that residents from the wider area can access it, they may not be welcomed by the new residents if they are paying a management company to look after it.
The Council’s target for north Reading, only 35 new homes per year are required to the year 2036. 260 is an unnecessary over-achievement and over-strains the infrastructure. Furthermore, there are alternatives to the proposal, e.g. according to the Council’s 2019 Brownfield Land Register, there are 138 sites totalling 134.25 hectares (many times than this site).
If this is approved, it would make it easier for the developer to get permission from Oxfordshire for the rest of the RGC land and it could precipitate a rash of building across Reading’s northern border.
There is no evidence of consultation with either SODC or Kidmore End Parish about the proposals for the open space, country park, tree planting and allotments that the applicant is asserting as fact.
The plan’s assumption of 2.9 occupants per household includes “empty-nesters” whereas the site’s new occupants will realistically have more children per household. This then skews all subsequent predictions regarding school places, health care, crime, etc.
We completely refute recent statements from the golf club regarding their so-called legacy. The legacy should not be judged purely on the strength of a country park and some allotments in a different county and an empty health centre. The legacy also includes increased traffic congestion, more pollution, reduction of air quality, insufficient school places, more GP waiting time and a loss of wildlife habitat. And it will not just be a legacy for Emmer Green. These problems will spread further afield to the rest of Caversham, including adding to everyone’s carbon footprint. Furthermore, this could be followed by another phase of house building on the club’s Oxfordshire land.
This application is ill-conceived. There are inconsistencies, basic arithmetical errors and extremely biased interpretations of data throughout and it is entirely non-compliant with many significant Council policies. Even the Council’s own officers question the competency of some of the reports.
If you share these concerns, please tell your Council. Thinking that it won’t change anything is not a good reason for doing nothing. Every objection letter or email will count. Every member of your household is entitled to send in an objection and you can repeat it as often as you wish. Numbers of objections received by the Council really matter – it gets their attention. Please stand up and be counted!
Once again, do NOT copy/paste the above words. The council will ignore your letter if you do. Please use your own words and include your address and the words “Planning Ref: 200713”.
Comment on http://planning.reading.gov.uk/fastweb_PL/detail.asp?AltRef=200713 or email to planning.comments@reading.gov.uk or write to Planning Dept, Reading Borough Council, Civic Offices, Bridge Street, Reading, RG1 2LU.
