Regulation 19 Objections to Loddon Garden Village (LGV).
- paulstevens24
- 3 hours ago
- 4 min read
Now that the Examination In Public (EIP) date has been set it feels appropriate to re-visit the arguments SOLVE Hall Farm has submitted to the Inspectors as to why we feel this plan is UNSOUND. These points have all been previously submitted, ahead of the deadline for comments, and it is expected that the Inspectors will allow us some time during the EIP to expand upon them. I personally will represent these points to the Inspectors, unless we can find people better qualified. It maybe that you are someone with a particular skill set or depth of knowledge about a particular aspect of the Local Plan. If so, do please get in touch. I fully expect to expand upon these topics over the next 6 weeks, and again, if you have anything to add to what is proposed, get in touch.
Paul Stevens for SOLVE Hall Farm.
1) Skewed sustainability appraisals.
Comparing the 2020 and 2021 Sustainability Appraisals, LGV improves its rating in several categories including Accessibility from 3 to 1, Air Quality from 3 to 2, Economy from 2 to 1 and Transport from 3 to1. This was highlighted by Bell Cornwell, the planning consultants commissioned by Arborfield & Newland Parish Council. There are a significant number of constraints with the LGV site, which did not appear to have been considered by the 2021 Sustainability Appraisal. In addition, the 2024 Sustainability Appraisal for the Reg 19 Submission Plan has seven scenarios. Six of these scenarios involve LGV in various combinations with other sites. Ashridge is shown as the only scenario without LGV. Twyford is only shown as an option with LGV. Why wasn’t Twyford a standalone option?
2) Sustainable Transport
Reading Borough Council remarked during the 2021/22 consultation “accessibility to central Reading and the rest of the urban area is currently extremely poor”. This proposal will encourage greater car use as there is no Public Transport available on site and expectations that people will cycle or walk are unsubstantiated. Very optimistic assumptions are being made on walking, cycling and bus use, given the demographics locally. No detail on how the move to public transport will be managed anywhere except cost estimates of what bus priority measures are to be implemented and the negative impact on traffic this will have. The degree of success in transfer to bus will rely heavily upon very high levels of bus priority measures which are yet to be detailed and tested. A strategic approach to transport requires significant investment in infrastructure. This may be possible if additional, national funding is made available, but no sign of a commitment from the current Labour administration to date.
3) Traffic
Recurring traffic problems are evident all around the LGV site, but are particularly bad at Mole Road, Mill Lane and Lower Earley Way. Also, major problems at university roundabout (formerly blackboy roundabout) in Shinfield and showcase roundabout in Winnersh. Basic traffic surveys are all taken in Nov 2021 which was very soon after the last lockdown and there has been a great deal of new development since then. We are asking WBC to share the more recent traffic modelling data but to date this has yet to happen.
Traffic congestion will be an even greater problem during the 20+ year building period, therefore if LGV is to go ahead then it is critical that the required road infrastructure should be delivered in advance of the housing.
4) Agricultural land at LGV
This site, as good quality agricultural land, has the potential to provide much needed community engagement and social enrichment alongside healthy, locally grown food. CPRE state that Maintaining agricultural capacity to deliver significant levels of domestic food production is critical for our national food security. 9.11.1 states that LGV likely includes significant BMV agricultural land. It goes on to say uncertainty exists as none of the site has been surveyed. Building on land classified as "Best and Most Versatile" (BMV) is generally not permitted under current planning policy.
5) Waste water treatment
The Water Treatment Plant for Arborfield is already overloaded during times of heavy rainfall and is known to pump untreated sewage into Barkham Brook. Thames Water, who are responsible for the required upgrade are in dire financial problems and may yet be put into special measures or returned to public ownership. House building should only commence following completion of the sewage treatment plant upgrades
6) Health and wellbeing
Medical services are already overstretched with the existing population. Arborfield Green SDL was “promised” a medical centre, but this has still not happened, despite the 3,500 houses built there. RBH location/date still not decided. New medical hub location/date also not yet decided. Local medical facilities do not meet current needs, never mind future needs. False claims about a medical service at Arborfield Village Hall have been used to support unsustainable development in Arborfield Cross.
7) Separation between settlements
As identified in the Arborfield and Barkham Neighbourhood Plan at IRS1. Paragraph 9 of the NPPF empowers local planning authorities to create distinctive local plans that take local circumstances, needs, and priorities into account. This allows for the designation of strategic and local gaps to maintain settlement separation where appropriate. The NPPF's overarching goal is to guide development towards sustainable solutions. This can include strategies to avoid the coalescence of settlements, thereby retaining open countryside and individual settlement identities.
8) Spatial Strategy
Green field development has been chosen over more sustainable brownfield alternatives. Having a new SDL as the primary means of achieving the housing delivery means that other more viable options are ignored e.g. land at Green Park
9) Financial viability
The Infrastructure Development Plan has significant inconsistencies and omissions in it, such that we are not persuaded of the projected costs. Insufficient account has been taken of the potential impact of inflation, shortages of labour and materials. The August 2025 updated version of the IDP shows an £80m difference compared to the infrastructure costs listed in the Financial Viability Assessment – September 2025

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