A case study on how representations to the Plan making process can improve policy wording
Extra Care is designed to support individuals who need assistance while promoting as much independence as possible. Unlike traditional residential care, this model combines secure housing with tailored support, allowing residents to maintain control over their lives while receiving the necessary help
As part of efforts to promote a site for retirement living accommodation within Bracknell, ET Planning submitted representations to Bracknell Forest Council and appeared at the Examination in Public to make sound certain elements of the Draft Plan.
Fig 1: Proposals for a 150 unit retirement village by C2PD. Image courtesy of EPR Architects
The case study – Strategic gaps
When Policy LP19 the policy was initially crafted, it designated strategic gaps to prevent the merging of settlements and protect open spaces. Our submission focused on the inclusion of the Land at Murrell Hill Grange, Murrell Hill Lane within the Bracknell – Wokingham strategic gap.
We successfully argued that the policy duplicated the Draft Local Plan’s countryside policy, as well as contradicting elements of its later living policy.
How did we do this?
Fig 2: The concept allows for residents to move within the village, as their care needs change. The village also included on-site facilities. Image courtesy of EPR Architects
In our representation, we highlighted several key reasons why the proposed strategic gap was unsound:
- Insufficient Justification for the Gap’s Extent
The current gap designation is overly broad and does not accurately reflect the specific characteristics of the area. Our detailed analysis revealed that the site, located approximately 660 metres from Wokingham (compared to 470 metres between the Amen Corner development and the Keephatch development in Wokingham), does not meaningfully contribute to the separation between Bracknell and Wokingham. - Inaccurate Assessment of the Site’s Role in the Gap
The council’s Sustainability Appraisal and Site Suitability Assessment identified the site as playing an important role in separating Bracknell and Wokingham. However, these assessments did not explicitly reference the ‘Binfield – Wokingham’ gap, which we believe is the more relevant gap to the site. Moreover, there was a lack of clarity in how the site was analysed in relation to the gap. Given its distance from Wokingham and the existing urban development to the south, we argued that the site does not fulfil the role of preserving the spatial separation of these settlements. - Contextual Changes in the Area
Since the initial site assessments were made, the surrounding area has undergone significant development. The Amen Corner development has altered the landscape and shifted the context in which the site is situated. We demonstrated that the site would not reduce the physical separation between Bracknell and Wokingham but would represent a natural extension of existing urban development. - Consistency with National Planning Policy
The National Planning Policy Framework (NPPF) requires planning policies to be flexible and responsive to local needs while facilitating sustainable development. We argued that the broad-brush approach of Policy LP19 fails to take account of site-specific circumstances, thereby unreasonably restricting development. We contended that the policy, as currently drafted, is not positively prepared and does not align with national planning policy, particularly in its failure to support sustainable development.
The final outcome?
Overall, we successfully argued that the policy does not meet the tests of soundness as set out in Paragraph 35 of the NPPF. In our written representations, we contended that the policy is too restrictive and fails to account for the specific characteristics of individual sites, such as the Land at Murrell Hill Grange. We demonstrated that by excluding this site from the Bracknell – Wokingham gap, the local plan would better align with national policy objectives, facilitate sustainable development, and ensure that the borough’s planning framework is both effective and flexible.
The council adopted its amended local plan in March 2024, which removed the Local Gaps policy. We continue to promote the site to the local authority as part of our ongoing work.
You can read Bracknell Forest Council’s adopted local plan here.
Need help promoting a Later living scheme?
If this is something which you feel ET Planning can support you with, please contact our in-house Strategic Planning Team for a free 15-minute consultation by Tuesday 1st April 2025.
Associate Director – David Wetherill david.wetherill@etplanning.co.uk
Senior Planner – Phil Williams – phil.williams@etplanning.co.uk
Alternatively, you can call ET Planning on 01344 508048 to arrange a consultation.