PLANNING APPLICATION FOR FILM STUDIOS ON "STROUD FARM"
FEBRUARY 2023  -  RBW Planning Ref 22/03374/OUT

In December 2022, after earlier publicity from the would be developers, the Planning Application identified above was made, seeking access to Stroud Farm for creation of what  the developers dared to call "Holyport Film Studios".  The access would be from Forest Green Road, and the buildings and car parks would be to the West of Gay's Lane, with an outside film area to the East at the South End of Gay's Lane.

This is an application for access only, with all other matters reserved, which means that should access be granted the applicant is free to change his plans, so we do not really know what would occur should access be granted.

We must never be mis-led by the words "for access only".  If access is granted then the development will go ahead.  "All other matters reserved" means that the developer has not committed to any of the other details.  For instance the land to be made open to the public may not materialise.

So for only one person has emailed me saying that they like the idea, because it would bring business to the area.  But we have seen evidence that it would result in very few jobs for local people.

As of 3rd February 2023 the RBWM Planning website shows 148 objections, and none in favour.

Below I show a map copied from Google Earth with notes and highlighting to show in blue dots the boundary of the Stroud Farm land proposed to be despoiled.

Red are buildings; Purple car parks or roads, Some buildings over 21 metres high (as pointed out by Bray Parish Council this is as high as four double decker buses stacked on each other) and at least 60,000 sq ft of buildings.

Click on the following links to see information about Film Studios at Shinfield.

Film Studios at Shinfield and threatened for Holyport

Dissatisfaction with Shinfield Studios

Some people have expressed concern as to how to object to the Film Studios Proposal, finding the amount of detail overwhelming.

We recommend not to get overly involved in reading or responding to the many documents provided.  Responding in such detail implies an acceptance that the development might proceed and that the comments would be considered to “improve” the application.  Our object is to completely prevent it, not improve it.

The main reason for objection is that to allow this development would contravene the Government’s rules expressed as “guidance” in the National Planning Policy Framework.  The NPPF can be found at https://www.gov.uk/guidance/national-planning-policy-framework   and the following remarks are all relevant to NPPF paragraphs that support our cause to have this proposal refused, and are included in the HRA objection which has already been made to RBWM and was emailed to members and friends on 4^th January.

1. The land is Green Belt so all of the paragraphs shown at the end of this email, copied from the National Planning Policy Framework support a refusal of this proposal.
2. The applicant states  "Each production brings together its own team of people including those from the “building trades” for set production, “technicians” such as camera operators, sound engineers, lighting etc, hair and wardrobe etc and post production activities such as editing, CGI etc, not to mention producers, directors, and the actors. When each production is completed, those people will disperse. Given the typical duration of productions, the progressive year on-year reduction in car usage sought by typical Travel Plan policy is unlikely to be achieved because no group of people will be permanently at the Site over that sort of timescale."  This indicates that there is little likelihood of employment for local people, and demonstrates that the project does not implement a sustainable traffic policy.
3. This development would bring a huge amount of new traffic and impose the resulting increase in air pollution upon the residents of this Green Belt area including Holyport Village conservation area, and especially those living on or near Forest Green Road, Moneyrow Green, Holyport Road, A308, A330, Gays Lane, John Gay’s House and Grounds, Langworthy Lane, Holyport Green.
4. This land is within the Metropolitan Green Belt, and has not been included in the RBWM Local Development Plan (LDP) as a developable area. In its LDP, RBWM has already removed areas from London Green Belt so as to allow them to be developed, including areas for industry such as this, so it would be inappropriate and unreasonable and against the principles expressed in the NPPF if RBWM were to allow development on any Green Belt land other than the sites already included in their LDP.
5. In the RBWM LDP, RBWM state that the Metropolitan Green Belt will be protected against “inappropriate development” and that planning permission will not be granted for “inappropriate development” unless very special circumstances are demonstrated.
6. The Green Belt guidance, which is in effect “regulations”, as outlined in the NPPF, being an expression of Government requirements, prohibit any development such as this on Green Belt land, unless there are “very special circumstances”.
7. This development proposal would cause sprawl, contribute to the merging of Holyport Forest Green and Fifield, cause encroachment, and change forever the current setting and special character of the Holyport Moneyrow Green and Forest Green area, including Holyport’s conservation area.  RBWM have not included this land for development in their Local Development Plan.  The RBWM Plan already includes more development, as housing, to meet the requirements of Central Government. In addition, the LDP includes areas for business use including former Green Belt Land between the A308(M), the M4 and the A330.
8. This proposed Green Belt development would be “inappropriate development in the Green Belt”.
9. There are no exceptional circumstances or “Very Special Circumstances” that could possibly be applied to this proposal. The applicant pretends that his failure to find another suitable area is a special circumstance.  To present this as a very special circumstance is unethical, and to agree with such an approach would be unethical and perverse.
10. There are no other considerations that can outweigh the harm that this development would cause. A community such as we have in the Holyport area, indeed any community whatsoever, is not obliged to accept a huge business development whose employees would have to travel there from elsewhere because the applicant pretends to be unable to find another location.
11. The non-conformance with all of the above NPPF Green Belt points make it impossible for a Planning Authority or the Planning Inspectorate to approve the proposed development, and it should be unnecessary for anyone objecting to the proposal to have to comment extensively against the multitude of information in the planning submission.
12. Should this proposal be accepted it would be in absolute contradiction of all logic as to the duty of care of a Local Authority and the Planning Inspectorate to protect the Amenity of residents in the area concerned.
13. Whilst following the guidance of the NPPF, as they are required to do, neither the Local Authority nor the Planning Inspectorate can approve this application.  Both of these parties should unequivocally refuse this application and send a clear message to developers that the NPPF guidance cannot be circumvented.

The following is quoted from the NPPF.

137. The Government attaches great importance to Green Belts. The fundamental aim
of Green Belt policy is to prevent urban sprawl by keeping land permanently open;
the essential characteristics of Green Belts are their openness and their
permanence.

138. Green Belt serves five purposes:
a) to check the unrestricted sprawl of large built-up areas;
b) to prevent neighbouring towns merging into one another;
c) to assist in safeguarding the countryside from encroachment;
d) to preserve the setting and special character of historic towns; and
e) to assist in urban regeneration, by encouraging the recycling of derelict and
other urban land.

147. Inappropriate development is, by definition, harmful to the Green Belt and should
not be approved except in very special circumstances.

148. When considering any planning application, local planning authorities should
ensure that substantial weight is given to any harm to the Green Belt. ‘Very special
circumstances’ will not exist unless the potential harm to the Green Belt by reason
of inappropriateness, and any other harm resulting from the proposal, is clearly
outweighed by other considerations.

149. A local planning authority should regard the construction of new buildings as
inappropriate in the Green Belt. Exceptions to this are:
a) buildings for agriculture and forestry;
b) the provision of appropriate facilities (in connection with the existing use of land
or a change of use) for outdoor sport, outdoor recreation, cemeteries and burial
grounds and allotments; as long as the facilities preserve the openness of the
Green Belt and do not conflict with the purposes of including land within it;
c) the extension or alteration of a building provided that it does not result in
disproportionate additions over and above the size of the original building;
d) the replacement of a building, provided the new building is in the same use and
not materially larger than the one it replaces;
e) limited infilling in villages;
f) limited affordable housing for local community needs under policies set out in
the development plan (including policies for rural exception sites); and

g) limited infilling or the partial or complete redevelopment of previously developed
land, whether redundant or in continuing use (excluding temporary buildings),
which would:
‒ not have a greater impact on the openness of the Green Belt than the
existing development; or
‒ not cause substantial harm to the openness of the Green Belt, where the
development would re-use previously developed land and contribute to
meeting an identified affordable housing need within the area of the local
planning authority.

174. Planning policies and decisions should contribute to and enhance the natural and
local environment by:
a) protecting and enhancing valued landscapes, sites of biodiversity or geological
value and soils (in a manner commensurate with their statutory status or
identified quality in the development plan);
b) recognising the intrinsic character and beauty of the countryside, and the wider
benefits from natural capital and ecosystem services – including the economic

and other benefits of the best and most versatile agricultural land, and of trees
and woodland;
c) maintaining the character of the undeveloped coast, while improving public
access to it where appropriate;
d) minimising impacts on and providing net gains for biodiversity, including by
establishing coherent ecological networks that are more resilient to current and
future pressures;
e) preventing new and existing development from contributing to, being put at
unacceptable risk from, or being adversely affected by, unacceptable levels of
soil, air, water or noise pollution or land instability. Development should,
wherever possible, help to improve local environmental conditions such as air
and water quality, taking into account relevant information such as river basin
management plans; and
f) remediating and mitigating despoiled, degraded, derelict, contaminated and
unstable land, where appropriate.

185. Planning policies and decisions should also ensure that new development is
appropriate for its location taking into account the likely effects (including
cumulative effects) of pollution on health, living conditions and the natural
environment, as well as the potential sensitivity of the site or the wider area to
impacts that could arise from the development. In doing so they should:
a) mitigate and reduce to a minimum potential adverse impacts resulting from
noise from new development – and avoid noise giving rise to significant adverse
impacts on health and the quality of life65;
b) identify and protect tranquil areas which have remained relatively undisturbed
by noise and are prized for their recreational and amenity value for this reason;
and
c) limit the impact of light pollution from artificial light on local amenity, intrinsically
dark landscapes and nature conservation.

Holyport Residents Association has objected on 16th December 2022 as follows;

Holyport Residents Association – First Objection to Planning Application 22/03374/OUT “Holyport Film Studios”

- Outline application for access only to be considered at this stage with all other matters to be reserved etc.

Holyport Residents Association (HRA) objects in the strongest possible terms to all of the proposals as described in Planning Application RBWM 22/03374/OUT.

We note that this application requests that access only be considered at this stage, whilst reserving all other matters so that these could later be changed.

This HRA objection is not merely to object against access being granted; it is to additionally object to the rest of the plans as so far revealed to us; and to object to the entire concept that an owner and / or developer might be permitted to impose such an inappropriate intrusion into our pleasant rural setting. This development would bring a huge amount of new traffic and impose the resulting air pollution upon the residents of this London Green Belt area including Holyport Village conservation area, and especially those living on or near Forest Green Road, Moneyrow Green, Holyport Road, A308, A330, Gays Lane, John Gay’s House and Grounds, Langworthy Lane, Holyport Green.

This land is within the London Green Belt, and has not been included in the RBWM Local Development Plan (LDP) as a developable area. In its LDP, RBWM has already removed areas from London Green Belt so as to allow them to be developed, so it would be inappropriate and unreasonable and against the principles expressed in the NPPF if RBWM were to allow development on any Green Belt land other than the sites already included in their LDP.

As some areas scheduled in the LDP for development were previously Green Belt and the LDP has included, for example, far more houses than are required by Central Government, we consider that it if RBWM were to allow the proposed business development on this or any other Green Belt land, such decision would be against the Government principles on Green Belt land as set out in the National Planning Policy Framework.

We consider that RBWM should make it known to all that here is no point in applying to build on London Green Belt land in the RBWM domain, and that RBWM should immediately reject, without any public consultation, any application for building on the Green Belt land within the RBWM remit.

We note that in the RBWM LDP the statement is made that the Metropolitan Green Belt will be protected against inappropriate development and that planning permission will not be granted for inappropriate development unless very special circumstances are demonstrated.

HRA has seen objections made by others and we support and agree with the content of all objections already made to this application. In the main we limit our observations to a demonstration that the Green Belt “regulations” as outlined in the NPPF, being an expression of Government requirements, prohibit any development such as this on London Green Belt land. Further, we state our support for any and all future public objections to this application and / or to any other applications made to build on London Green Belt land in the RBWM area.

Looking at the National Planning Policy Framework (NPPF) we see as follows, quoted in italics; (our notes added in red and our underlining)

First – NPPF regarding businesses

84. Planning policies and decisions should enable:
a) the sustainable growth and expansion of all types of business in rural areas, both through conversion of existing buildings and well-designed new buildings;

(This is over-ruled by Green Belt Considerations – and also because the proposed business is not an existing local business – further the buildings and car parks and outside film areas would be inappropriate, overbearing and unsightly.)

b) the development and diversification of agricultural and other land-based rural businesses; (This proposal would change from agricultural to non-related troublesome business use so this does not apply; additionally, this is not a development of an existing local business.)

c) sustainable rural tourism and leisure developments which respect the character of the countryside;

(Over-ruled by Green Belt Considerations and business is not tourism and not leisure – not applicable.)
and d) the retention and development of accessible local services and community facilities, such as local shops, meeting places, sports venues, open space, cultural buildings, public houses and places of worship.

(Over-ruled by Green Belt Considerations and not applicable.)
85. Planning policies and decisions should recognise that sites to meet local business and community needs in rural areas may have to be found adjacent to or beyond existing settlements, and in locations that are not well served by public transport.

(This proposal is not a development of an existing local business or local business need and would not meet local employment needs as most employment would come from outside the area.)

In these circumstances it will be important to ensure that development is sensitive to its surroundings, does not have an unacceptable impact on local roads

(This proposal would cause increased vehicular traffic and traffic pollution in what is already an air polluted area. The proposals mention parking for 80 lorries and 1000 cars of which 420 would be in multi-story and 560 outside.)

and exploits any opportunities to make a location more sustainable (for example by improving the scope for access on foot,

(five existing footpaths would be adversely affected making access and current amenity of countryside walking experience worse.)

by cycling or by public transport). The use of previously developed land,

(land is agricultural and has not been previously developed)

and sites that are physically well-related to existing settlements, should be encouraged where suitable opportunities exist.

(Over-ruled by Green belt Considerations and not applicable.)

We consider that the non-conformance with all of the above NPPF business points make it impossible for a Planning Authority or the Planning Inspectorate to approve the proposed development.

Second – NPPF regarding Green Belt Matters

137. The Government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence.

138. Green Belt serves five purposes: - we quote four relevant to this case below;

a) to check the unrestricted sprawl of large built-up areas;
b) to prevent neighbouring towns merging into one another;
c) to assist in safeguarding the countryside from encroachment;
d) to preserve the setting and special character of historic towns;
 

(This development proposal would cause sprawl, contribute to the merging of Holyport Forest Green and Fifield, cause encroachment, and change forever the current setting and special character of the Holyport Moneyrow Green and Forest Green area, including Holyport’s conservation area.)

140. Once established, Green Belt boundaries should only be altered where exceptional
circumstances are fully evidenced and justified, through the preparation or updating
of plans. (“plans” in this context means Borough Local Development Plans) Strategic policies should establish the need for any changes to Green Belt boundaries, having regard to their intended permanence in the long term, so they can endure beyond the plan period. (there are no RBWM Strategic policies that could require such development.)

RBWM have not included this land for development in their Local Development Plan.  The RBWM Plan already includes more development, as housing, to meet the requirements of Central Government. In addition, the LDP includes areas for business use including former Green Belt Land between the A308(M), the M4 and the A330.

Thus, this proposed Green Belt development would be “inappropriate development”.

147. Inappropriate development is, by definition, harmful to the Green Belt and should
not be approved except in very special circumstances.

There are no exceptional circumstances or “Very Special Circumstances” that could possibly be applied to this proposal. The applicant pretends that his failure to find another suitable area is a special circumstance.  To agree with such an approach would be unethical and perverse.

148. When considering any planning application, local planning authorities should ensure that substantial weight is given to any harm to the Green Belt. ‘Very special circumstances’ will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm resulting from the proposal, is clearly outweighed by other considerations.

There are no other considerations that can outweigh the harm that this development would cause. A community such as we have in the Holyport area, indeed any community whatsoever, is not obliged to accept a huge business development because the applicant claims to be unable to find another location.

149. A local planning authority should regard the construction of new buildings as inappropriate in the Green Belt. Exceptions to this are:

a) buildings for agriculture and forestry;
b) the provision of appropriate facilities (in connection with the existing use of land
or a change of use) for outdoor sport, outdoor recreation, cemeteries and burial
grounds and allotments; as long as the facilities preserve the openness of the
Green Belt and do not conflict with the purposes of including land within it;
c) the extension or alteration of a building provided that it does not result in
disproportionate additions over and above the size of the original building;
d) the replacement of a building, provided the new building is in the same use and
not materially larger than the one it replaces;
e) limited infilling in villages;
f) limited affordable housing for local community needs under policies set out in
the development plan (including policies for rural exception sites); and
g) limited infilling or the partial or complete redevelopment of previously developed
land, whether redundant or in continuing use (excluding temporary buildings),
which would:
‒ not have a greater impact on the openness of the Green Belt than the existing development; or
‒ not cause substantial harm to the openness of the Green Belt, where the
development would re-use previously developed land and contribute to
meeting an identified affordable housing need within the area of the local
planning authority.

None of these listed exceptions are applicable to the proposed development with its extensive traffic intentions).

150. Certain other forms of development are also not inappropriate in the Green Belt
provided they preserve its openness and do not conflict with the purposes of
including land within it. These are:
a) mineral extraction;
b) engineering operations;
c) local transport infrastructure which can demonstrate a requirement for a Green
Belt location;
d) the re-use of buildings provided that the buildings are of permanent and
substantial construction;
e) material changes in the use of land (such as changes of use for outdoor sport or
recreation, or for cemeteries and burial grounds); and
f) development, including buildings, brought forward under a Community Right to
Build Order or Neighbourhood Development Order.

None of these listed exceptions are applicable to the proposed development with its extensive traffic intentions).

180. When determining planning applications, local planning authorities should apply the
following principles:
a) if significant harm to biodiversity resulting from a development cannot be
avoided (through locating on an alternative site with less harmful impacts),
adequately mitigated, or, as a last resort, compensated for, then planning
permission should be refused;

The area proposed for development contains much wildlife which would be destroyed.

We consider that the non-conformance with all of the above NPPF Green Belt points make it impossible for a Planning Authority or the Planning Inspectorate to approve the proposed development, and we believe that it should not be necessary for anyone objecting to the proposal to have to comment extensively against the multitude of information in the planning submission.

Should this proposal be accepted it would be in absolute contradiction of all logic as to the duty of care of a Local Authority and the Planning Inspectorate to protect the Amenity of residents in the area concerned.

However, further to the above we comment below on certain matters advised in the application.

Regarding the Alternative Sites Assessment – this being presented as an attempt to use the “Very Special Circumstances” consideration, we consider that the supposed lack of any other place to put this proposed film studio is not valid as a “Very Special Circumstance”.

The multitude of assessments of other sites presented in this application with the object of showing that only the Holyport Area is suitable is not valid as a mitigating factor.

No resident, no Local Authority, no Government department, no-one whatsoever is under any obligation to accept an imposition such as is proposed here because the applicant pretends that there is no other place for it.

The applicant refers to this proposal as being part of the “West London Cluster” of film studios (Note that our area is within the London Green Belt) and that it will be one of the largest studios of that ilk.

They say that they have access to further land and refer to the expanding film production industry; and that the location being within a 45-minute drive from London is a factor in choosing the location.  That further land to which they have access may be that shown bounded by the blue line in the 22_03374_OUT-LOCATION_PLAN-2701831.pdf.  If so then this is further reason to resist this imposition upon local residents.

Further they refer to the good access from the M4 for lorries and state that they are providing space for the parking of 80 lorries and 1000 cars of which 420 would be in multi-story and 560 outside.  There is mention of “Large operational vehicles” on Site B.  Horse riders, walkers, wildlife and livestock would all be adversely affected.

The main entry would be from Forest Green Road (to the West of the track leading to Gay’s Lane). Staff for studios such as these usually travels from afar. For example, observe the extensive parking arrangements on the A308 for the existing Bray Studios.

This development proposal would mean much more traffic on whatever route the drivers might choose from the following routes to the proposed site, and returning;

From M4 Junction 8/9;

The A308, A330, the A330 through Holyport and passing Holyport Academy, Forest Green Road.

Or A308, Holyport Road, Moneyrow Green, Forest Green Road.

Or from M4 Junction 7;

The A308, Oakley Green Road, Forest Green Road.

Or A308 passing / visiting Bray Film Studios, Fifield Road, Forest Green Road,

Or A308 passing / visiting Bray Film Studios, Holyport Road, Moneyrow Green, Forest Green Road.

Or A308, Oakley Green Road, Forest Green Road.

All of the aforementioned routes are already congested, some with 30 mph limits which are mostly not complied with, and are not suitable for the proposed increased traffic. The applicant mentions collaboration with Bray Studios, and that employees work long 15-hour days.  This latter means that this development would result in a massive increase in traffic (cars and lorries) around the clock.

All of these reasons for this location reinforce the concept that this development means a very great deal of new traffic including large lorries, together with the pollution caused by such traffic. Pollution measurement in the area already demonstrates that it is high – and there is thus very good reason not to encourage further traffic.

The Forest Green area, including some lanes and bridle-ways which cross the intended site, and Forest Green Road is used by horse owners and stable facilities, including the teaching of horse-riding.  The roads also see horse transports and many cyclist platoons.

The proposed buildings would put footpaths and bridle-paths in the shade and thus contribute to muddiness of footpaths and bridle-paths.

Local ponds have Great Crested Newts and it is known that these creatures migrate from and through damp areas such as those already present throughout the intended development area.

There would be light and noise pollution to houses on Moneyrow Green and Forest Green Road (Old Beams, Amys Cottage, Rustlers View and FirLawn Cottage).  Deer have been seen in the fields of and transiting through both Site A and Site B.

There is reference to the backlot which would allow for parking of all types of vehicles associated with outside filming.  Backlots are busy and this is shown as being next to the “Nature Park” and properties on Green Lane.

There is mention of a Cricket Ground, which would reduce the area available for normal public access.  Our area already has sufficient cricket grounds and no parking is indicated for the mentioned cricket ground or for the public park proposals.  As this application keeps all matters other than access reserved there is no commitment to build the cricket ground or any other public areas.

As financial aspects stand in Britain, we need to produce more of our own food, so converting agricultural land into film studios is not a good idea. Further, global warming and resultant climate change is happening and rising sea levels will come. That will result in reduced land area and disruption of world-wide food production as well as general chaos, so a further reason to conserve what food producing land we have.  We already have too much traffic and pollution.

The Environment Agency flood maps show that the area is susceptible to flooding.  This is also borne out by local experience.  In periods of heavy rain, groundwater currently accumulates in this area often being surface water and gradually feeds through to Langworthy Lane, Moneyrow Green and Holyport Green and the Cut.  New buildings, roads and hardstanding will make matters worse.

If these fields are built on then residences in these areas may be badly affected where the run off increases and causes increase flooding risk of properties.

Flooding is a definite concern in this area, and there is worldwide recognition that climate change is bringing a more water saturated environment.  This will result in a raised water table, and in the long term, higher sea level will further raise the water table. The addition of buildings and associated new roads contributes to an environment more susceptible to flooding, and we know that the sewage system is already overloaded.

This application being currently for access only, together with the mention in the applicant’s design statement of a Travel Plan and a Transport Statement, we expect to review these, which must be appropriate for access matters, but as of the date of this representation they do not appear in the documents on the RBWM website.

We consider that as a point of principle for Local Authority Planning, if a planning application does not contain all of the documents that are intended to, or are required to be submitted, then the Authority should not formally accept the application and should not commence the consultation process until all documents have been submitted.  Further, if the applicant submits further documents during or after the consultation period the consultation period should be extended or re-opened.

We consider that, whilst following the guidance of the NPPF, as they are required to do, neither the Local Authority nor the Planning Inspectorate can approve this application.

HRA concludes that we have provided sufficient reason why this proposal and all such proposals for development of Green Belt land not included in the Borough Local Development Plan must be refused. We may make further representations should we consider these necessary.

Holyport Residents Association has objected again on 30th January 2023 as follows;

Holyport Residents Association – Second Objection to Planning Application 22/03374/OUT “Holyport Film Studios”

- Outline application for access only to be considered at this stage with all other matters to be reserved etc. – in relation to 22/02796 EIASCR

Further to our first objection to this application, Holyport Residents Association (HRA) is now aware of advice which, in a response to 22/02796 EIASCR, RBWM’s Environmental Protection Officer gave to the applicant regarding environmental issues.

The text provided to the applicant by RBWM is as follows (our underlining);

“We would not have any objections in principle to this development if a full application were to be made. The main issues would be loss of amenity with respect to noise and lighting.

The supporting information suggests that an acoustic assessment will be carried out which can be supported by a standard condition. As well as being directed towards the possible detrimental effects of associated plant machinery from building services such as ventilation, heating and extraction, attention should also be directed towards traffic noise and onsite traffic movement including forklift trucks etc close to the areas where residential properties are located. As indicated, acoustic assessment should be carried out to current industry best practice and British Standards.

A full application should be supported by submission of lighting details and assurance in the form of assessment that outside lighting such as flood lighting will not lead to a loss of amenity.

A Construction Environmental Plan will be requested to be conditioned to protect residents during the construction phases of this development which will include standard dust, noise and vibration control and will have standard construction and construction delivery hours.

Although not thought to be an issue, with developments of this size on agricultural farm land, an unknown contamination condition would be requested which is actioned only if unexpected ground conditions are encountered.”

It is lamentable that the first sentence of the RBWM advice gives reason to believe that the application can be approved, and that advice is then given as to how to submit an application likely to succeed.  We strongly object to the RBWM approach, and now refer to the RBWM Environmental Protection Policies EP1, 2, 3, 4 and 5 quoted below.  Parts of these, as underlined by us, are in clear contradiction to the RBWM advice.

Policy EP 1 Environmental Protection

1. Development proposals will only be supported where it can be shown that either individually or cumulatively in combination with other schemes, they do not have an unacceptable effect on environmental quality or landscape, both during the construction phase or when completed. Development proposals should also avoid locating sensitive uses such as residential units, schools or hospitals in areas with existing or likely future nuisance, pollution or contamination.
2. Where appropriate, applicants will be required to submit details of remedial or preventative measures (for example: construction management plans) and any supporting environmental assessments. Planning conditions may be imposed to ensure implementation of any measures that make development proposals acceptable.
3. Development proposals should seek to conserve, enhance and maintain existing environmental quality in the locality, including areas of ecological value (land and water based), and improve quality where possible, both during construction and upon completion. Opportunities for such improvements should be incorporated at the design stage and through operation.
4. Residential amenity should not be harmed by reason of noise, smell or other nuisance. Accordingly, care should be taken when siting particular commercial or agricultural proposals such as livestock units, silage storage or slurry pits which should be sited well away from the curtilage of any residential property.

Policy EP 2 Air Pollution

1. Development proposals will need to demonstrate that they do not significantly affect residents within or adjacent to an Air Quality Management Area (AQMA) or to residents being introduced by the development itself.
2. Development proposals which may result in significant increases in air pollution must contain appropriate mitigation measures, (such as green infrastructure, sustainable travel, electric vehicle charging parking points, limited vehicle parking, awareness raising, and enabling smarter travel choices) thus reducing the likelihood of health problems for residents.
3. Development proposals should aim to contribute to conserving and enhancing the natural and local environment, by avoiding putting new or existing occupiers at risk of harm from unacceptable levels of air quality. Development proposals should show how they have had regard to the UK Air Quality Strategy or any successive strategies or guidance, ensuring that pollutant levels do not exceed or come close to exceeding national limit values.
4. Development proposals should show how they have considered air quality impacts at the earliest stage possible; where appropriate through an air quality impact assessment which should include the cumulative impacts. Where relevant, air quality and transport assessments should be linked to health impact assessments, including any transport related mitigation measures that prove necessary.

Policy EP 3 Artificial Light Pollution

1. Development proposals should seek to avoid generating artificial light pollution where possible and development proposals for new outdoor lighting schemes that are likely to have a detrimental impact on neighbouring residents, the rural character of an area or biodiversity, should provide effective mitigation measures. Development proposals which involve outdoor lighting must be accompanied by a lighting scheme prepared according to the latest national design guidance and relevant British Standards publications.
2. Development proposals should seek to replace any existing light installations in order to mitigate or reduce existing light pollution.
3. The distinction between urban areas and the countryside should be maintained. To determine whether development proposals involving artificial lighting have a detrimental impact, they should be assessed in accordance with the zone in which they are located (E2, E3 or E4) on whether they have the potential to cause harm to the health or quality of life, or to affect biodiversity.
4. All artificial lighting must be directional and focused with cowlings to reduce light spill into river corridors and other wildlife corridors.
5. Development proposals should show how they have addressed the environmental zone in which the application is proposed and suggest mitigation measures and methodology accordingly and will also require where appropriate development proposals include landscaping measures to effectively screen lighting installations. The use of overly sensitive ‘movement triggered' lighting will be resisted where it would impact on the amenity of the area.
6. With particular reference to floodlighting schemes, development proposals should not have an adverse effect on adjacent areas and use suitable methods for data provision, such as an isolux diagram.

Policy EP 4 Noise

1. Development proposals should consider the noise and quality of life impact on recipients in existing nearby properties and also the intended new occupiers ensuring they will not be subject to unacceptable harm.
2. Development proposals that generate unacceptable levels of noise and affect quality of life will not be permitted. Effective mitigation measures will be required where development proposals may generate significant levels of noise (for example from plant and equipment) and may cause or have an adverse impact on neighbouring residents, the rural character of an area or biodiversity.
3. Development proposals in areas significantly affected by aircraft, road or rail noise will be supported if the applicant can demonstrate via a noise impact assessment, effective mitigation measures.
4. Development proposals will need to demonstrate how they have met the following internal noise standards for noise sensitive developments:
   1. Internal noise levels within all habitable rooms shall not exceed an average noise level (LAeq) of 35 dB(A) during the daytime measured between 07.00am to 11.00pm
   2. Internal noise levels within all habitable rooms shall not exceed an average noise level (LAeq) of 30 dB(A) during the night – time measured between 11.00pm and 07.00am
   3. Internal noise levels within the bedroom environment shall not exceed a maximum noise level (LAmax) of 45 dB(A) during the night – time measured between 11.00pm and 07.00am
   4. Where feasible, measures shall be taken to ensure the external noise levels as part of the development do not exceed an average noise level (LAeq) of 55 dB(A) during the daytime measured between 07.00am and 11.00pm

These noise standards will apply unless there are particular specific circumstances that justify some variation to be made in individual cases.

5. The Council will require noise impact assessments to be submitted in circumstances where development proposals will generate or be affected by unacceptable levels of neighbourhood or environmental noise.

Neighbourhood Noise

6. Where neighbourhood noise associated with a particular development is likely to cause unacceptable harm to existing or future occupiers, the Council will require applicants to submit a noise assessment.
7. Development proposals will be expected to demonstrate how exposure to neighbourhood noise will be minimised by the use of sound insulation, silencers, noise limiters, screening from undue noise by natural barriers, man made barriers or other buildings and by restricting certain activities on site.

Environmental noise

8. Development proposals will need to carry out a noise impact assessment in compliance with BS7445-1: 2003 for development proposals affected by environmental noise, to determine the noise levels that affect the development, and will also need to submit noise insulation and ventilation measures in compliance with BS8233. In addition noise mitigation measures will also need to be adopted to provide some protection of outdoor amenities from excessive noise levels from road and rail noise.

Policy EP 5 Contaminated Land and Water

1. Development proposals will be supported where it can be demonstrated that proposals will not cause unacceptable harm to the quality of groundwater, including Source Protection Zones, and do not have a detrimental effect on the quality of surface water. Development proposals should demonstrate how they will achieve remedial or preventative measures and submit any supporting assessments.
2. Development proposals on, or near to land which is, or is suspected to be contaminated will be supported where the applicant can demonstrate that there will be no harm arising from the contamination to the health of future users or occupiers of the site or neighbouring land, and that the proposals will not cause unacceptable harm to the environment.
3. Development proposals will be reviewed under pollutant linkage (source-pathway-receptor) risk assessments which should be represented by a conceptual model for the proposed use. The Council will liaise with the Environment Agency and water companies where appropriate, in relation to measures that affect surface and groundwater.
4. Development proposals will be supported where it can be demonstrated that adequate and effective remedial measures to remove the potential harm to human health and the environment are successfully mitigated.

We comment on the underlined sections below;

EP1 (1) It cannot be shown that the proposals will not have an unacceptable effect.

EP1 (4) Residential amenity would definitely be harmed by noise and other nuisance.

EP2 (1) It cannot be shown that the development will not affect existing residents within and adjacent to local AQMA’s.

EP 3 (1) It is impossible to prevent the light pollution that this development would bring.

EP 3 (3) The area is countryside and the proposal would urbanise it – therefore it cannot be permitted.

EP 4 (1) The harm due to noise produced and the resultant and other reduced quality of life which this development would cause would be unacceptable.

EP 4 (2) This statement is absolutely specific - noise would be unacceptable and quality of life affected so the development is prohibited.

EP 4 (8) New noise would result from the predicted traffic and there is no way that the effect of that noise can be mitigated.

EP 5 (1) It cannot be demonstrated that unacceptable harm will not be caused to the quality of groundwater and surface water.

The other text of the Environmental Policies is made irrelevant by the fact of the impossibility to comply with the underlined parts as commented upon above.

We complain here that in the RBWM website for 22/02796 EIASCR there is no copy of any RBWM letter giving RBWM answer to the applicant.  But the conclusion is “No Objection”.

We conclude that the planning application 22/03374/OUT must be rejected.

On 20th January at a public meeting Bray Parish Council recommended refusal as shown below;

BPC Recommends Refusal for the following reasons:-

1. Not in the RBWMs Borough Local Plan for Development
2. According to Government Agricultural Classification (ALC), Stroud Farm is considered high quality
agricultural land. The Government sets out to protect the best and most versatile (BMV)
agricultural land from significant, inappropriate or unsustainable development proposals. As
Identified in NPPF Conserving and enhancing the natural environment – paragraphs 174 to 188.
3. Green belt, no very special circumstances have been provided to justify the destruction of the
openness of the Green Belt by the height of 21m+ and mass of at least 60,000sqft of buildings.
Citing not able to find elsewhere is not applicable, for application no. 18/03725/FULL on the same
land as the proposed main development, the Shooting Club cited the reason of not being able to
find anywhere else for VSP - this application was Dismissed at Appeal. The Inspector decided the
very special circumstances necessary to justify the development do not exist. The proposal would,
therefore, be contrary to the aim of the Framework to protect Green Belt land and would conflict
with Policies GB1 and GB2 of the Local Plan, where they are consistent with the Framework. This
development is much larger than this one.
4. Green Belt; Parkland area: Application no. 19/00362 to change from Agricultural to Education, part
of the area outlined to be a Park was Dismissed at Appeal due to the proposal being contrary to the
then Policies GB1, GB2, DG1, T5 and N6 of the LP, Policies SP5, SP3, IF2 and NR2 of the emerging
plan as well as the Framework.
The creation of a Parkland would urbanise the area, currently open farmland fields, and a change of
use would open the door to future development.
There is a mention of a cricket pitch on this land; as there is one behind Holyport Memorial Hall and
one at Braywood, another one is not required.
5. Green Belt: closing the gap between villages of Holyport and Fifield as boundary for Stroud Farm by
Green Lane is the edge of Holyport. Bray Parish Residents wish to keep gaps between the villages
and for the villages not to merge – RBWM supports this in the BLP.
6. Impact on Holyport’s Conservation Area and Historic Listed buildings. RBWM are committed in the
BLP to protect Historic Buildings and Conservation areas, this development is near to Grade II listed
building, John Gays House, and the Conservation Area boundary. The openness and trees setting in
Langworthy lane with its surrounding area and lack of heavy traffic is identified positive in that part
of the Conservation Area.
7. Proposed development area is known to Flood; in their objections residents have provided photos
of recent flooding on the fields identified for development. As the climate is getting warmer, one of
the downsides is that Winters will be wetter, so flooding is now a regular occurrence for the future.
8. Moneyrow Green the past few years has had issues with flooding; Thames Water has done
extensive work to clear pipes etc. but it is common knowledge that the current Thames Water
network cannot take anymore development in the area. Understand there is no money available
to facilitate a multimillion-pound upgrade. Both Thames Water and Environmental are aware of
this application and should be RBWM consultees for this development, if they have not been
contacted already, due to its large size and impact on the area.
9. Wildlife: Been already identified that there are Great Crested Newts, which are protected, in the
area. The creation of the development would have a negative impact on them and to local wildlife
in general, this includes Hedgehogs which are also endangered. There are also regular sightings of
Barn Owls, Red Kites, Buzzards, Foxes, Deer etc – the whole area is a natural wildlife park as the
land is agricultural and should be protected as such.
10. Light Pollution: it should be noted there is currently none at the moment as its open farmland
fields. If you drive by Bray Studios at night you will see it dramatically lit up with, at times, 50m
high cranes to carrying high lighting rigs. The proposed site will need to have security lighting and
as it’s a 24hr operation we envisage it will require high lighting rigs too – as this is currently farm
land and an undeveloped area, this increase in lighting will be seen for miles around and impact
many residents and any wildlife left.
11. Reduction and impact of local pathways/bridleways – for the record Gays Lane and Green Lane are
NOT lanes for general vehicular traffic they are officially Bridleways, as is Primrose Lane. This whole
area is a very popular area for Horse Riders as the area is peppered with Polo and Livery Yards, with
the charity for Children Windsor Horse Rangers, which is near the proposed roundabout next to
Green Lane Bridleway. Many Dog Walkers and Cyclists use the footpaths etc too enjoying the open
countryside as it is considered an important asset to the residents who use them and to their
wellbeing – noted in many of the residents’ objections. Off road use wherever possible should be
encouraged as surrounding roads have no footpaths, therefore we should be preserving these
important footpaths not removing them with any development.
12. Developers are waiting to see how this application progresses. The reality is, if approved, they are
likely to put forward surrounding land for development; allowing this application sets a precedent
for using Green Belt thereby opening the door for others to follow in both Holyport and Fifield for
starters.
13. Sustainability: the applicant has not provided a business model to justify this
development. Concern as there currently are around 11 x Film/TV studios within a close proximity
of the development which are either built, being built, extended or at application stage. Not
forgetting of course Bray Studios extension, which should be noted has its access off an A road:
Bray (extension agreed in progress of being built) – 2.5 miles
Pinewood - 11.6 miles
Shepperton – 14.2 miles
Arborfield – 13.4 miles
Winnersh – 12.5 miles
Langley – 10.7 miles
Shinfield (being built) – 16 miles
Fleetwood – 15.7 miles
Longcross – 11.1 miles
Wycombe (being built) – 12.5 miles
Marlow (Proposed) – 9.4 miles
You have to question if this level of building for this industry can continue to be profitable; or is it a
cynical ploy to develop the land in general as, if approved and not sustainable, the next step would
be to apply for housing.
14. Jobs: it is well known that in the Film/TV industry they use specialist contactors for each set, so
local jobs creation will be limited unless the contractors live in the area. In this area there tends to
be a lack of people for roles, not lack of jobs – ask any employer in the area.
15. Traffic: Forest Green Road is a B road with blind bends, hills etc. in fact, where the proposed
roundabout is sited is at the brow of a hill next to Green Lane bridleway and next to a S bend =
dangerous. If you ask residents in the area, they will advise of many accidents in the past from farm
traffic exiting the current access.
Access to this area will be by:
a. M4 J8/9; down Ascot Road (with narrow throat unsuitable for large vehicles/HGVs by
*Holyport Green) past Holyport College and then left into Forest Green Road. Forest Green
Road is a road with no footpaths and verges only and near the Jolly Gardener there is a one
way only bridge not suitable for large amount of HGVs visiting this site – this road already
has had subsidence maintenance on the sides of the road and is narrow and winding.
*It should be noted that Holyport Green is under Private Ownership of BPC.
b. If large HGVs cannot get through on Holyport Green via Ascot Road, coming off the
M4 they will go down Windsor Road. Then turn right into Holyport Road towards Holyport
green, turning left towards Moneyrow Green by a children’s playground, Holyport Cricket
Club, Holyport Memorial Hall and then left by Jolly Gardener.
c. M4 J6 Windsor turning; then down towards A308 Maidenhead Road and then onto
*Windsor Road. Turning left into Oakley Green Road down past Braywood CE First School,
Braywood Cricket Club and onto Forest Green Road, past busy road junction with Fifield
Lane.
*At this part of Windsor Road there are several large housing developments proposed on
Windsor Road, notably AL21 which is forecasted to have 450 houses, a school etc.
NONE of the above routes are suitable for this amount of additional traffic – in the applicants
documents they are forecasting to have parking for 80 x Lorries and 1,000 Cars, of which 420
are to be in a multi storey car park.
Within the BLP there is intensive building already planned in the area which will dramatically
impact the traffic on the above routes and surrounding areas.
The Triangle Site AL14 on Ascot Road is set to be developed and the Syngenta Jealotts Hill
science park toward Bracknell is currently under consultation for 2,000 houses - if approved,
this development could dramatically increase the traffic using the Ascot Road onto the M4 etc.
Proposer – Cllr Kneen
Seconder – Cllr Pellew
Vote – Unanimous