Inspectors questions for WBC​
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Below are extracts from a letter sent to Wokingham Borough Council Head of Planning Policy Ian Bellinger from the two Independent Inspectors appointed by the Secretary of State to conduct the Examination in Public: Thomas Hatfield BA (Hons) MA MRTPI and Mark Philpott BA (Hons) MA MRTPI
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Dear Mr Bellinger,
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EXAMINATION OF THE WOKINGHAM LOCAL PLAN UPDATE
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1. Further to the submission of the Wokingham Local Plan Update, we have begun our initial reading of the Plan, the supporting evidence and representations.
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2. Based on what we have read so far, we have several initial questions and requests for further information and clarification, which are set out below. The Council’s responses to these will help to inform the matters, issues and questions (MIQ’s) and the remaining timetable for the examination.
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3. At this stage, and based on the submitted evidence, we have particular concerns about the delivery of housing including in relation to Loddon Valley Garden Village. It may be necessary to hold early hearing sessions in relation to these matters.
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4. Please could the Council provide a note on the phasing assumptions that have been applied to this site that addresses the following matters:
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The milestones that would need to be achieved in order for the first dwellings to be delivered in financial year 2026/27. This should include the timescales for securing full planning permission, discharging of pre-commencement planning conditions, finalisation of an agreed masterplan and other strategies (as required by Policy SS13), and completion of upfront infrastructural works.
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The evidence and assumptions that underpin the assumed annual delivery rates set out in the Housing Trajectory (HO8).
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For comparison, the lead in times and annual delivery rates achieved at the SDLs allocated in the Core Strategy Local Plan (2010).
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The following highway and energy infrastructural improvements are described as being either ‘critical’ or ‘essential’ for LVGV in the Infrastructure Delivery Plan (‘IDP’) (IN7), and each has an indicative cost of more than £10 million. What are the delivery timescales for these infrastructural improvements, and how many dwellings could be occupied before each is completed?
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Bridge over the M4 motorway
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Bridge over the River Loddon
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Loddon Valley pedestrian bridge
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Dual carriageway connection to Meldreth Way roundabout o Arborfield Primary Sub-Station capacity upgrade
5. Table 7.4.1 of the Local Plan Viability Study (VI1a) itemises the infrastructural requirements for the LVGV site. However, the costs that are listed here differ significantly from those provided in the IDP for the same items. Why is this the case?
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6. Table 7.4.1 of the Local Plan Viability Study excludes most of the infrastructure listed for the LVGV site in the IDP. In particular there is no reference to highway works (around £140 million), community facilities (£5.3 million), sub-station capacity upgrades (£16.8 million), sports facilities (£15.2 million), and open space (£10.6 million). Have these infrastructural costs been considered in the Viability Study? If not, has LVGV been subject to any other site-specific viability testing that considers the infrastructural costs set out in the IDP?
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7. Would LVGV also be required to contribute towards any of the ‘critical’ or ‘essential’ infrastructure identified as ‘Borough wide’ in the IDP in order to mitigate its highway impacts?
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8. What are the costings in the IDP relating to LVGV based on? Do they reflect current prices?
9. Will all planning permissions within LVGV be required to contribute to the delivery of the infrastructure identified in the IDP? How will the contribution from each scheme be calculated? How will the delivery of this infrastructure be coordinated?
10. The Council’s response to the Regulation 19 representations (CD4f) states that a planning application for this site is “due to be submitted in 2025”. Is this likely to be an outline or full application?
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These 10 points indicate a serious concern by the inspectors regarding the viability of the Loddon Garden Village to deliver the housing and infrastructure promised. The letter goes on to take issue with some of the assumptions made in the plan regarding flood risk, particularly from sewage:
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32. The Statement of Common Ground (‘SoCG’) between the Council and the Environment Agency (WBC4) specifies that a review of new flood zone data (which was seemingly subsequently published on 25 March 2025) needs to be undertaken to ascertain whether there are any implications for the Plan. When is this review anticipated to be completed?
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33. The SoCG indicates that the Environment Agency has outstanding concerns regarding the delivery of capacity improvements to the Arborfield Sewage Treatment Works. Thames Water and the IDP indicate that improvements will be delivered between 2025-2030. Have these improvements been secured? Please provide any relevant documentation which sets this out.
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34. Appendix A of the Level 2 Strategic Flood Risk Assessment 2 (‘SFRA2’) (EN3a) suggests that sewer flooding, which is not mapped, is a constraint at the LVGV site. It also indicates that safe access and egress is not possible in a 1% annual exceedance percentage plus 40% climate change surface water event. Are these points addressed in the evidence?
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You can read the letter in full here:
https://www.localplanservices.co.uk/_files/ugd/017f5b_bf3e31059d5b4eb6a0e9033f42a7230e.pdf
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Below is a short video created by friends of SOLVE Hall Farm showing the proposed M4 bridge that will be needed to take traffic out of the site. As highlighted by the Inspectors in their letter the delivery date and true cost of this bridge have not been fully explained within the plan. Nor have the environmental impacts of thousands more cars being pushed onto Lower Earley Way.​​​