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Representations raised on behalf of The Trustees of Market Reading Field in response to the Chiltern and South Bucks Local Plan Green Belt Preferred Options Consultation

December 2016

© TIM NORTH & ASSOCIATES LIMITED COPYRIGHT 2016 No part of this publication may be reproduced by any means without the permission of Tim North & Associates Ltd

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PREAMBLE These representations have been prepared on behalf of The Trustees of Market Reading Field, the owners of a parcel of land situated off Eagle Close, Quill Hall Lane, Amersham, Buckinghamshire HP6 6LL, in response to the Chiltern and South Bucks Local Plan Green Belt Preferred Options Consultation October – December 2016.

This response is required to be read in conjunction with earlier representations made on behalf of the same owners to the Chiltern and South Bucks Local Plan Initial Consultation Incorporating Issues and Options under Regulation 18 of the Town & Country Planning (Local Planning) (England) Regulations 2012. The earlier representations comprised a stand-alone document directed at planning considerations, alongside a separate Transport Sustainability and Access Feasibility Study prepared by PFA Consulting Plc; both documents proposing a mixed use or composite development on Market Reading Field.

The earlier representations set out the landowners aspirations to create a small sustainable urban extension (hereinafter referred to as a SUE) to the main settlement of Amersham, catering for around 60 dwellings; a large area of public open space; 625 sq.m (6727 sq.ft) of Class B1(a)/(b) business units; along with a doctor’s surgery accommodating five practitioners.

These subsequent representations comprise two separate parts.

The first section is directed at those fundamental concerns surrounding the approach taken in arriving at the 15 preferred sites or options for removal from the Metropolitan Green Belt. These concerns do not relate to the underlying methodology chosen, which has resulted in the 15 preferred sites or options being identified for release from the Metropolitan Green Belt. The issue is whether the two Councils by pursuing an approach in identifying sites or options for removal from the Metropolitan Green Belt, independently from a comprehensive assessment of the extent to which their full objectively assessed housing needs (hereinafter referred to as FOAN) can be met in their respective administrative areas, has resulted in a restricted selection of reasonable alternatives in meeting both Councils’ FOAN.

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Implicit in this approach is whether, consciously or not, the extent of unmet housing needs required to be accommodated in the adjoining Authority is greater than would otherwise be the case, had a more robust exercise been undertaken into satisfying both Councils’ FOAN in their respective administrative areas.

The approach taken by the two Authorities is best illustrated by the Foreword to the Green Belt Options Consultation document in which it is said:-

“A key part of the Local Plan will be to explore options for meeting development needs in the Green Belt that cannot be met within built areas, on previously developed land, nor can be met in areas outside of Chiltern and South Bucks. This work is not yet complete but has progressed sufficiently for Preferred Options to be identified and tested through public consultation. “

There is a clear implication in this statement, that the approach is to concentrate firstly on built up areas, then previously developed land, then areas outside of Chiltern and South Bucks District Council, before lastly considering releases of land from the Metropolitan Green Belt in Chiltern and South Bucks DCs’ administrative areas. The strategy is flawed in that it places reliance on meeting unmet needs in an adjoining authority’s area, before contemplating the release of land to better meet Chiltern and South Bucks District Councils’ FOAN. It is contended the last two stages should be reversed.

This is particularly important seen in the context of a key issue to emerge from a summary of consultation responses identified by the Council’s consultants Golder Associates to the Vale of Aylesbury Consultation Draft Plan, in which overwhelming support was recorded from residents and other parties located in Aylesbury Vale District Council’s administrative area, for that Authority when contemplating providing for potentially 12,000 new homes to meet the unmet needs in South Buckinghamshire and High Wycombe, “to robustly challenge this allocation through the commissioning of an independent investigation into other areas’ allocation figures.”

The second section of these representations considers the manner in which the site known as Market Reading Field, given Reference No. 4.085 was assessed in accordance with the selected methodology, following the submission of representations on behalf of the Trustees of Market Reading Field to the Chiltern & South Bucks Local Plan Initial Consultation Incorporating Issues & Options. A number of inconsistencies emerge from your Councils’ assessment of my client’s site.

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The detailed representations raised on behalf of the Trustees of Market Reading Field went beyond an assessment of those parameters comprising the “The Buckinghamshire Green Belt Assessment Report: Methodology and Assessment of General Areas” prepared by Ove Arup & Partners, to incorporate a pre- and post-mitigation assessment matrix as part of a Sustainability Appraisal. In this way, the earlier representations raised on behalf of the Trustees of Market Reading Field went beyond issues surrounding Part 1 of the Buckinghamshire Green Belt Assessment, to include matters the subject of what is termed Part 2 of the same Green Belt Assessment where it relates to land in Chiltern and South Bucks District Councils’ administrative areas.

This point aside, it is my client’s view that no proper consideration was given to the contents of the submitted representations, including the ability of the same land to meet unmet local needs. In particular, no attention was paid to assessing Market Reading Field as part of a recommended “sub-area” to General Area 22b. This is in spite of the Issues and Options document prepared under Regulation 18 of the Town & Country Planning (Local Planning) (England) Regulations 2012, showing the same land along with Quill Hall Farm, as one of four larger potential extension options to Amersham. Furthermore, at time when there is an absence of any firm commitment by the adjoining Authority to meet all of the unmet housing needs derived from Chiltern and South Bucks District Councils, no consideration was given to Market Reading Field as a potential “safeguarded (white) land” site.

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IMPORTANT ISSUES ARISING FROM THE APPROACH IN IDENTIFYING THE 15 PREFERRED SITES OR OPTIONS

One of the spatial strategies set out in the Issues and Options Consultation Document was Option C, suggesting built up extensions to a number of principal settlements in the two Councils’ administrative areas; Amersham being one of those settlements. A total of four built up area extension options were promoted in the case of Amersham, one of which comprised land known as Market Reading Field and Quill Hall Farm.

The evidence base at the time of publication of the Issues and Options Consultation document included the “Buckinghamshire Green Belt Assessment Part 1A: Methodology” prepared by Ove Arup & Partners and dated 11th August 2015. The detailed assessment of individual “General Areas” of the Metropolitan Green Belt against the purposes of a Green Belt, together with the respective pro-forma assessment were not available to third parties at the time the consultation process on the Issues and Options document commenced.

A separate document entitled “The Buckinghamshire Green Belt Assessment Report: Methodology and Assessment of General Areas” was published by Ove Arup & Partners on 7th March 2016. This document consolidated the individual Green Belt assessments undertaken by the same consultants on behalf of Aylesbury Vale DC, Wycombe DC and Chiltern and South Bucks DCs. It covers the entire Green Belt in Buckinghamshire, being one comprehensive document reproducing the information set out in “The Buckinghamshire Green Belt Assessment Part 1A: Methodology” where it relates to South Bucks and Chiltern DCs’ administrative areas.

The only differences between the two Buckinghamshire Green Belt Assessments where they concern the methodological approach in assessing potential releases of land from the Green Belt, concern three areas. Firstly, several non-Green Belt and Green Belt settlements omitted from earlier maps were added. Secondly, non-Green Belt settlements have now been set out in their entirely in a table. Thirdly, a minor alteration has been made to Footnote 21 where it concerns “Purpose 3: To assist in safeguarding the countryside from encroachment”. In respect of the last issue, Footnote 21 in “The Buckinghamshire Green Belt Assessment Part 1A: Methodology” stated:

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“For example, General Areas with a relatively low level of built form (i.e. between 20-30%) and a largely rural character would score 3; however a General Area with a relatively low level of built form (i.e. between 20-30%) but with an urban character (such as formal open space designation covering the entire General Area) would score 1. In practice, these revisions only applied to a few General Areas as the character and the percentage of built form were generally aligned, as per the score definition.”

In its place, Footnote 30 of “The Buckinghamshire Green Belt Assessment Report: Methodology and Assessment of General Areas” said:

“For example, General Areas with a relatively low level of built form (e.g. less than 10%) and a largely rural character would score 3; however a General Area with a relatively low level of built form (e.g. less than 10%) but with an urban character (such as formal open space designation covering the entire general Area) would score 1. “

Whilst no issues arise from these minor amendments to the methodology set out in the “The Buckinghamshire Green Belt Assessment Report: Methodology and Assessment of General Areas” of 7th March 2016; four important considerations emerge from this consolidated document which are of concern to my clients, in that they have had a direct impact on the approach taken in preparing the Chiltern and South Bucks Local Plan Green Belt Preferred Options Consultation October-December 2016.

Firstly, the report published by Ove Arup & Partners on 7th March 2016 occurred 7 days prior to the end of the consultation period on 14th March 2016 where it relates to the Chiltern & South Bucks Local Plan Issues & Consultation Document. This later Green Belt Assessment document incorporates all suggested releases from the Metropolitan Green Belt in the four Local Planning Authorities’ areas, for which Local Plans are currently being prepared.

The consolidation into one document of all potential releases of land from the Metropolitan Green Belt cannot fail to have an impact on the approach taken with respect to the Part 2 Green Belt Assessments in Chiltern and South Bucks District Councils’ administrative areas, raising questions over whether pre-determination has played a role in preparing the Part 2 Assessment, influencing the conclusions set out in the Green Belt Preferred Options Consultation Document October-December 2016.

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Secondly, in the knowledge that Aylesbury Vale District Council is relatively unconstrained in terms of landscape designations, including the Metropolitan Green Belt, has the effect, whether consciously or not, of adopting a restrictive approach when undertaking the Part 2 Assessment of Green Belt sites suggested for release to meet future housing and other development needs in Chiltern and South Bucks DCs’ administrative areas.

This leads onto a third issue, namely the identification of sub-areas to those “General Areas” forming part of the “The Buckinghamshire Green Belt Assessment Report: Methodology and Assessment of General Areas”; an issue of particular relevance to land in my client’s ownership located on the north eastern fringes of the built up area of Amersham.

The Part One process found that every “General Area” met the NPPF purposes to some extent, with the majority of the Buckinghamshire Green Belt performing an important role in terms of the NPPF purposes. Ove Arup & Partners categorised a number of areas which performed more weakly and which warranted further consideration. These categorised areas were as follows:

• General Areas which score weakly overall against the NPPF purposes;

• Whole General Areas or clusters of General Areas which, although medium or strongly scoring against the NPPF purposes, have particular characteristics or synergies with neighbouring weaker General Areas; and

• Medium or strongly scoring General Areas where there is clear scope for sub- division to identify weakly performing “sub-areas” including the presence of boundary features which have the potential to be permanent or recognisable.

The Part One Buckinghamshire Green Belt Assessment Report published on 7th March 2016 identified eight “Recommended General Areas”, all of which were in Chiltern or South Bucks DCs’ administrative areas. It also identified 31 “recommended sub-areas”; 23 of which are in Chiltern and/or South Bucks Districts, being those set out in Table 6.1,

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Map 6.1a, Map 6.1b and Sections 6.2 – 6.4 of the “The Buckinghamshire Green Belt Assessment Report: Methodology and Assessment of General Areas”.

It is understood that the overall purpose of the Part Two Assessments is to consider through more detailed requirements the appropriateness of any adjustments to the Green Belt boundary in respect of those areas identified in the “The Buckinghamshire Green Belt Assessment Report: Methodology and Assessment of General Areas” dated 7th March 2016, as well as proposals made in response to the Issues and Options Regulation 18 Consultation Document, including the “Call for Sites”.

There is, however, no background document which identifies to those persons who have made representations to the Issues and Options Regulation 18 Consultation Document, how your Authorities have categorised those areas set out in the three bullet points above. This is particularly important in the context of the third bullet point, which is pertinent to the release of land at Market Reading Field from the Metropolitan Green Belt to meet identified local needs. The sub-division of the north eastern urban extension to Amersham, previously forming part of Option C, concentrating solely on Market Reading Field, leads to a “sub-area” in which all boundary features would have the potential to be permanent and recognisable, even if they are not considered to be so at present.

Fourthly, and as a result of the previous three reasons, the Green Belt Assessment document produced by Ove Arup & Partners on 7th March 2016 occurred at a time when all four Authorities were producing their Local Plans, with the consequence that it influences the process adopted by Chiltern and South Bucks Councils in their consideration of the amount of land to be released from the Metropolitan Green Belt to meet their FOAN.

This in turn places Aylesbury Vale District Council in a somewhat invidious position, in being confronted with having to meet an unmet housing need arising in Wycombe, Chiltern and South Bucks District Councils’ administrative areas, whilst adhering to sustainability objectives. It casts doubts on whether the same unmet housing needs could not otherwise be met in Chiltern and South Bucks District Councils’

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administrative areas, should a different approach, or planning judgement, be taken in defining those areas to be released from the Metropolitan Green Belt.

If, as accepted, there is a need for consistency when examining the possible release of land from the Metropolitan Green Belt as part of any Green Belt Assessment covering South Buckinghamshire; equally, it is important that a separate exercise be carried out to examine the extent to which various levels of the FOAN can be met within Chiltern and South Bucks DCs’ administrative areas. It is only through carrying out this exercise that the full implications arising from the release of different quantities of land from the Metropolitan Green Belt to meet identified local needs can be effectively assessed.

The relevance of this exercise becomes apparent at a time when the Chiltern and South Bucks Local Plan Green Belt Preferred Options envisages only a minimal release of land from the Metropolitan Green Belt amounting to 1.4%, at a time when only 41% of its FOAN can be met within the two administrative areas.

There is no indication forming part of the Green Belt Preferred Options document as to the nature of those strategic priorities involved in respect of unmet needs where they have cross-boundary implications. In ascertaining exceptional circumstances from a national Green Belt perspective, requires at least the need to identify and grapple with the following matters: (i) the acuteness/intensity of the objectively assessed need; (ii) the inherent constraints on supply/availability of land, prima facie suitable for sustainable development; (iii) the consequent difficulties in achieving sustainable development in Chiltern and South Bucks District Councils’ administrative areas without impinging onto Green Belt; (iv) the nature and extent of harm to the Metropolitan Green Belt in the two Authority areas; and (v) importantly seen in the context of land owned by the Trustees of Reading Market Field, the extent to which consequent impacts on the purposes of this part of the Metropolitan Green Belt may be ameliorated or reduced to the lowest reasonably practicable extent.

The above considerations are materially relevant factors when seen in the context of paragraph 83 of the NPPF, and the first stage approach set out in the Court of Appeal

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judgement involving St Albans City and District Council v Hunston Properties Ltd and Another (2014) JPL 599; re-endorsed in the Court of Appeal judgement Solihull Metropolitan Borough Council v Gallagher Estates Ltd and Lioncourt Homes Ltd (2014) EWCA Civ 1610 in which Laws LJ endorsed the earlier conclusion of Hickinbottom J in the Court below, namely that:-

“Paragraph 47 requires full housing needs to be objectively assessed, and then a distinct assessment made as to whether (and, if so, to what extent) other policies dictate or justify constraint.”

Furthermore, these comments cannot be divorced from the requirement of Section 33A of the Planning & Compulsory Purchase Act 2004 concerning the legal Duty to Co-operate in relation to the planning of sustainable development. This process will require your two Authorities, amongst other matters, to ensure that the engagement is not only constructive from the outset, but is active and on-going, and that there has been mutual benefit in terms of strategic matters and priorities which are required to appear at the top of the list.

Whilst this does not require Councils to agree, it does require demonstration of at least the achievement of mutual benefit. This latter requirement as part of the Duty to Co-operate does not appear to have been robustly considered, given the nature of key issues arising from representations to the Vale of Aylesbury Consultation Draft Plan.

These considerations must have implications on the extent to which the 15 preferred sites or options now promoted for release from the Metropolitan Green Belt as part of the Chiltern and South Bucks Local Plan Green Belt Preferred Options Consultation October- December 2016, can be said to comply with the Duty to Co-operate with neighbouring authorities.

In considering these four issues, the NPPF identifies Green Belt as a constraint which may prevent an Authority from meeting its objectively assessed needs for housing. However, national policy does not prohibit an Authority from revising Green Belt boundaries, subject to it being done in exceptional circumstances through a Local Plan, and having regard to the need to promote sustainable patterns of development.

To this end, the notion that a revision of Green Belt boundaries is inherently unsustainable, is fundamentally incorrect, as it is to rely on Ministerial Written Statements which indicate

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that unmet housing needs are unlikely to represent the “very special circumstances” necessary to justify inappropriate development in a Green Belt. Case law has stated that the “very special circumstances” test where it concerns planning applications, is a stricter burden of proof than exceptional circumstances when considering the removal of land from a Green Belt in a Local Plan.

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INCONSISTENCIES IN THE APPROACH IN EVALUATING LAND KNOWN AS MARKET READING FIELD IN THE PART TWO GREEN BELT ASSESSMENT

The overall purpose of the Part Two Assessments undertaken on behalf of the four Local Authorities in South Buckinghamshire is to consider through more detailed requirements the appropriateness of any adjustments to the Green Belt boundary in respect of those areas identified in “The Buckinghamshire Green Belt Assessment Report: Methodology and Assessment of General Areas”, as well as proposals made in response to the Issues and Options Regulation 18 Consultation Document, including the “Call for Sites”.

It is noted from the Chiltern and South Bucks Green Belt Assessment Part Two Draft Report October 2016 that its scope has been considerably widened to include strategic options and areas of search involving Green Belt land that form part of Regulation 18 Public Consultation document; submissions made in response to previous (2015) Call for Sites public consultations, and submissions made to the 2016 Regulation 18 public consultation on the Chiltern and South Bucks Local Plan.

It is with these considerations in mind that I have reproduced as part of these representations the two documents which comprised the earlier representations to the Chiltern and South Bucks Local Plan Initial Consultation Incorporating Issues and Options under Regulation 18 of the Town & Country Planning (Local Planning) (England) Regulations 2012, in that whether looked at individually or in combination, they comprise more than an assessment of the purposes of the Green Belt when applied to the same site, being of equal importance when considering any Part Two Assessment.

Market Reading Field has its own Reference No. 4.085, which also forms part of the proposed north east extension to Amersham referred to in Reference No. 2.03 under the title “Amersham – Quill Hall Farm Area”. It is noted that both areas of land have been included in the Green Belt Assessment Part Two.

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Particular account has been taken of the Potential Boundary Assessment comprising Stage 1 of the Part Two Green Belt exercise, against which “General Areas” were identified. These areas include not only railway lines pertinent when considering the boundary to Market Reading Field, but also other additional durable boundary features, particularly in and around non-Green Belt settlements, including amongst others “protected woodland or hedgerows”. (my emphasis)

Appendix 1 to the Chiltern and South Bucks Green Belt Assessment Part Two Draft Report of October 2016 sets out the comments from Ove Arup and Partners as a critical friend on the draft methodologies to be employed in the Part Two Green Belt Assessment. Although the title to Appendix 1 relates to the Draft Green Belt Assessment Part Two carried out by Aylesbury Vale DC and Wycombe DC in July 2016; it is however apparent from the contents of paragraph 1.13 of the Chiltern and South Bucks Green Belt Assessment Part Two Draft Report of October 2016 that these comments are equally applicable to the Part Two Green Belt Assessment undertaken by your Councils.

Ove Arup highlight in their comments as a critical friend, certain important considerations when assessing potential boundaries in respect of Stage 1 of the Part Two Green Belt Assessment:-

“We have concerns about sub-areas being removed from the assessment process prematurely as a result of this assessment, particularly given the boundary features identified for consideration in para 3.6 does not feel exhaustive. We would suggest that this list is reviewed and/or expanded to take into account the differing scale of this Study compared with Part 1.

Furthermore, we believe that ruling out sites where a complete and strong defensive boundary cannot be identified would not be robust and could lead to challenges where sub-areas might otherwise be identified as suitable/available/achievable through the HELAA assessment. We suggest that a greater element of professional judgement should be employed in cases where only limited mitigation would be required to ensure a readily recognisable boundary can be identified. This would be in line with legal advice that other clients have received in relation to the potential to create new boundaries and enshrine the requirement to do so in planning policy or SPDs such as development briefs. Furthermore, we suggest that this assessment is used to identify how

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preferential a sub-area would be for potential release, rather than ruling areas out in a blanket fashion.”

The response from your Authorities accepts the need for a consistent approach to boundaries in Parts One and Two of the Green Belt Assessment, at the same time accepting that the use of professional judgement occurs where only limited mitigation would be required to identify a readily recognisable boundary that is likely to be permanent. The same response adds:

“… In addition, the Chiltern and South Bucks Part Two report states that further consideration may be given to the potential to create new Green Belt boundaries as part of the overall decision-making process for site allocations as part of the new local plan.“

These important considerations have been incorporated into the Chiltern and South Bucks Green Belt Assessment Part Two Draft Report October 2016 in paragraph 3.5, and with respect to “sub areas” to “General Areas” in paragraph 3.7:-

“3.5 The same approach has been adopted in the Part Two Assessment. This did not preclude the use of professional judgement where only limited mitigation would be required to identified a readily recognisable boundary that is likely to be permanent. Further consideration may be given to the potential to create new Green Belt boundaries as part of the overall decision-making process for site allocations as part of the new local plan.

3.7 … The Part Two Assessment has (with the exception of the Arup RGAs) considered areas of land smaller than the General Areas identified in Part One. It was therefore necessary to consider whether the purpose scores for the whole of the General Area in Part One should be adjusted for any sub-area being considered in Part Two: in other words, does the sub-area score differently when considered in isolation from the rest of the General Area in which it is located?”

The purpose of re-submitting the representations where they form part of the Issues and Options stage is to highlight the significance given to the above points which have not been addressed in the case of land owned by the Trustees of Market Reading Field. It is evident from a site inspection that with limited mitigation measures, strong defensible boundaries can be formed in the case of the land owned by my clients should Market Reading Field form a “sub-area” to General Area 22b.

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It is noted that the exercise of creating “sub areas” arose as part of the Part 1 Green Belt Assessment in respect of a site known as RSA-8 (General Area 23a – west of Amersham), but for some unknown reason the same exercise was not carried out with respect to Market Reading Field, despite resulting in the formation of a recognisable and defensible “sub-area” to General Area 22b. No explanation was given for this omission, despite the comprehensive representations raised on behalf of the Trustees of Market Reading Field as part of the Regulation 18 exercise.

Figures 5a and 5b comprise part of the Summary of Findings where they relate to the Stage 1 Potential Boundary Assessment forming part of the Part Two Green Belt Assessment. Figure 5a is entitled “Stage 1 Assessment – Areas where it is possible to identify a potential NPPF compliant boundary (considered further in Stage 2)”. Figure 5b is given the title Stage 1 Assessment – Areas where it is not possible to identify a potential NPPF compliant boundary (not considered further)”. The land the subject of Market Reading Field is shown in both these figures, resulting in a contradictory outcome.

Table 5 of the Chiltern and South Bucks Green Belt Assessment Part Two Draft Report October 2016, lists those areas of land where it is not possible to identify a potential NPPF compliant Green Belt boundary at Stage 1. The list includes Reference Nos 4.084 – Quill Hall Farm (larger site) and 4.085 Market Reading Field, Amersham, (i.e. land in the ownership of the Trustees of Market Reading Field to which these representations relate). However, when combined, these two parcels form the overall majority of the land which is referred to Reference No. 2.03 Amersham Quill Hall Farm area, which passed the Stage 1 Assessment and proceeded onto Stage 2, again revealing contradictions in the assessment.

A reading of the boundary assessments for Reference No 4.085 and Reference No. 2.03 highlights the flawed nature of the Part Two Assessment as it concerns my client’s land. It is said under the boundary assessment for 4.085:-

“It is not possible to identify a boundary that is permanent and defensible in accordance with NPPF requirements. The southern boundary of the proposed site is formed by properties outside of the Green Belt gaining access from Quill Hall Lane. The proposed site boundary then moves north east alongside the Metropolitan Railway Chesham branch line following an area of tree planting

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between the proposed site boundary and the railway land. The site boundary follows the railway line to the north west and then cuts south following an established field boundary hedge before re-joining the property boundaries off Quill Hall Lane. A large part of the proposed site boundary follows a strip of woodland planting between the site and the railway line. As the woodland strip forms a buffer to the railway whilst it is not protected woodland its presence in association with the railway could be regarded as a defensible permanent boundary. However, the western boundary is a normal field hedge and cannot be regarded as a permanent defensible boundary. As such it is not possible to define a permanent defensible NPPF compliant boundary for this site.”

In contrast, the boundary assessment of 2.03 Amersham Quill Hall Farm area, which includes the entire area of land forming part of Market Reading Field, read as follow:-

“It is possible to identify a boundary that is permanent and defensible in accordance with NPPF requirements. The boundary of the site follows the Metropolitan Chesham Branch line as its outer boundary whilst the inner boundary is the back gardens of properties in the existing built up area and follows the existing Green Belt boundary.

It can be seen that the only difference between these two assessments is what is referred to as the western boundary of the land the subject of 4.085, which it is said, is a “normal field hedge”.

Views towards the western boundary of Market Reading Field

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Views along footpath towards the bridge over the Chesham branch line where it forms the western boundary of Market Reading Field

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This description of the western boundary is inaccurate, in that it comprises a clearly definable footpath within a clearing, bounded by two separate hedgerows, and supplemented with semi mature tree planting, as a site visit will confirm. This boundary at present prevents intervisibility between the land known as Market Reading Field and that referred to as Quill Hall Farm.

Moreover, this potential boundary assessment has taken no account of the important comments raised by Ove Arup and Partners as a critical friend, subsequently incorporated into the Chiltern and South Bucks Green Belt Assessment Part Two Draft Report October 2016 at paragraph 3.7, namely the need to examine “sub-areas” of “General Areas” where with limited mitigation, existing recognised boundaries can be reinforced and identified to achieve identified land suitable for inclusion within the HELAA assessment.

More important is the fact that by divorcing Market Reading Field from Quill Hall Farm, results in a “sub area” which will achieve markedly different scores in terms of the purposes of the Green Belt, in comparison with the scores should both parcels of land be combined, as is the case with Reference No. 2.03. The representations raised on behalf of the Trustees of Market Reading Field to the Chiltern and South Bucks Local Plan Initial Consultation Regulation 18 version, undertook a comparison of the results seen in terms of Green Belt functions between the “sub-area” known as Market Reading Field with other General Areas found on the fringes of Amersham.

The difference in scores is such as to result in Market Reading Field proceeding onto the third stage of the Part Two Assessment, if only because the same land would not score strongly against one or more of the Green Belt purposes. It follows that the “sub area” of Market Reading Field would not contribute to the outward sprawl of a large built up area into open land, resulting in an encroachment into the surrounding countryside.

On the contrary, as the initial representations raised to the Issues and Options Regulation 18 document confirmed, Market Reading Field comprises an area of scrubland, devoid of agricultural use and where all its boundaries are delineated by

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deciduous and coniferous tree planting. It does not display any strong sense of openness or visual connection with the surrounding countryside.

A pre-mitigation and post-mitigation Sustainability Appraisal also formed part of the initial representations, highlighting the view that further consideration ought to have been given to Market Reading Field for inclusion as a mixed use SUE to Amersham in the emerging Chiltern and South Bucks Local Plan.

I trust that these representations will be considered by your Officers alongside the response raised on behalf of the Trustees of Market Reading Field to the Chiltern and South Bucks Local Plan Initial Consultation incorporating Issues and Options under Regulation 18 of the Town & Country Planning (Local Planning) (England) Regulations 2012.

-o0o-

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Representations raised on behalf of The Trustees of Market Reading Field in response to the Chiltern and South Bucks Local Plan Initial Consultation Incorporating Issues and Options under Regulation 18 of the Town & Country Planning (Local Planning) (England) Regulations 2012

March 2016

© TIM NORTH & ASSOCIATES LIMITED COPYRIGHT 2016 No part of this publication may be reproduced by any means without the permission of Tim North & Associates Ltd

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MARKET READING FIELD, AMERSHAM

TRANSPORT SUSTAINABILITY & ACCESS FEASIBILITY STUDY

THE TRUSTEES OF MARKET READING FIELD

MARCH 2016

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DOCUMENT CONTROL

Job No L409

Name Date Initials

Prepared By A M Waites 09.03.2016

Checked By P J Tregear 10.03.2016

Issue Date Comments Approved

Issue 01 10.03.2016 For Client Comments P J Tregear

Issue 02 11.03.2016 For submission P J Tregear

This document has been prepared for the exclusive use of the client in connection with the project and its copyright remains vested in PFA Consulting. Unless otherwise agreed in writing by PFA Consulting, no person or party may copy, reproduce, make use of or rely upon its contents other than for the purposes for which it was originally prepared and provided.

Opinions and information provided in this document have been provided using due care and diligence. It should be noted and is expressly stated that no independent verification of any information supplied to PFA Consulting has been made.

Warning: This document may contain coloured images which may not print satisfactorily in black and white. It may also contain images originally created at a size greater than A4 which may not print satisfactorily on small printers. If copying is authorised but difficulty is incurred in reproducing a paper copy of this document, or a scaled copy is required, please contact PFA Consulting. Authorisation for reproducing plans based upon Ordnance Survey information cannot be given.

© PFA Consulting Ltd 2016

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PAGE NO.

1. INTRODUCTION ...... 1 General ...... 1 2. EXISTING TRANSPORT CONDITIONS ...... 3 Site Context ...... 3 Existing Highway Network ...... 3 Walking and Cycling ...... 5 Public Transport ...... 6 Local Bus Services ...... 6 Rail Services ...... 9 3. SUSTAINABILITY ...... 10 Local Facilities ...... 10 Education ...... 12 Employment ...... 14 Health ...... 14 Leisure ...... 14 Food Retail ...... 14 Summary ...... 14 Sustainability Appraisal of the Chiltern and South Bucks Local Plan Initial Consultation (Regulation 18) Incorporating Issues and Options: Lepus Consulting – January 2016 ...... 14 Summary ...... 16 Census Data ...... 16 Mitigation ...... 17 Summary & Conclusion ...... 18 4. ACCESS FEASIBILITY ...... 19 Introduction ...... 19 Proposed Vehicular Access ...... 19 Proposed Pedestrian and Cycle Access ...... 21 Trip Generation ...... 21 Summary & Conclusion ...... 22 5. SUMMARY AND CONCLUSIONS ...... 24

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FIGURES Figure 1.1 Site Location Figure 2.1 Existing Bus Routes Figure 3.1 Local Facilities Figure 3.2 2km Isochrone Figure 3.3 Initial Route Option for Proposed Bus Service Figure 3.4 Ward Boundary Map

APPENDICES Appendix A Indicative Masterplan Appendix B PFA Drawing No. L409/3 Visibility at Quill Hall Lane / Eagle Close Junction Appendix C Extent of Public Highway Appendix D PFA Drawing No. L409/1 Proposed Site Access

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1. INTRODUCTION General 1.1. This Transport Sustainability & Access Feasibility Study has been prepared by PFA Consulting on behalf of The Trustees of Market Reading Field to support representations to Chiltern District Council and South Bucks District Council in respect of the initial Issues & Options consultation being undertaken as part of the emerging joint Chiltern and South Bucks Local Plan (2014-2036).

1.2. The proposed development site, known as Market Reading Field (identified as site CD0046 in the Chiltern District & South Bucks District ‘Draft Housing & Economic Land Availability Assessment’: January 2016) is located as shown on Figure 1.1. An indicative masterplan is reproduced at Appendix A.

Figure 1.1: Site Location

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1.3. The site is bound by the Metropolitan Underground line to the east, a public footpath with fields to the west and Quill Hall Lane and residential development to the south.

1.4. The proposed development is being promoted as mixed-use, to include approximately 60 residential units, 625m2 gfa of B1(a) / B1(b) in the form of units no greater than 125m2 and a doctor’s surgery (nominally 5 doctors).

1.5. Section 2 of this report undertakes a review of the existing transport network including opportunities for walking, cycling and public transport. Section 3 provides an assessment of the site’s sustainability when considering access to everyday services and facilities that the future residents / employees may need to access and also a review of the ‘Sustainability Appraisal of the Chiltern and South Bucks Local Plan’. Section 4 considers the opportunities for access to the site and provides a preliminary vehicle access design along with the estimated trip generation of the proposed development. Section 5 sets out the conclusions of the assessment.

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2. EXISTING TRANSPORT CONDITIONS Site Context 2.1. The site covers an area of approximately 8.97 hectares and is irregular in shape.

2.2. The Metropolitan Underground line, which is a single track branch line to Chesham Underground station, forms the eastern site boundary, to the west are fields while Quill Hall Lane and residential development is to the south. The site is within the Metropolitan Green Belt and the Chilterns AONB. The location of the site is shown on Figure 1.1 above.

Existing Highway Network 2.3. The proposed vehicular access into the proposed development will be taken from Eagle Close which is an adopted highway. Eagle Close is a single 5.5m wide carriageway with a single 2m wide footway and is street lit. Eagle Close currently serves 10 residential units and has an extant planning permission for 2 additional dwellings. The initial length of road from Quill Hall Lane is shown in Photograph 2.1.

Photograph 2.1: Eagle Close looking south-west to Quill Hall Lane

2.4. Eagle Close is accessed from Quill Hall Lane. PFA Drawing No. L409/3 reproduced at Appendix B shows that 2.4 x 43 metre visibility splays, in accordance with the requirements for traffic speeds of 30mph as set out in the Department for Transport (DfT) document ‘Manual for Streets: 2007’, can be obtained.

2.5. To the south Quill Hall Lane is an adopted 5 – 6 metre wide single carriageway road with footways on both sides and is street lit. The road is ‘traffic calmed’ with a set of five road humps. Quill Hall

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Lane provides vehicular access to residential properties and a Jewsons builder’s yard near the junction of Raans Road to the south.

2.6. Raans Road is a single carriageway road of approximately 6 metre width with a single 1.2m wide footway on the northern side of the carriageway and is street lit. Raans Road is adopted highway to approximately 250m beyond the railway bridge but is a no through road. It serves the Corinium industrial estate to the south and a proposed small housing state to the north.

2.7. Raans Road provides access to the Raans Road / Woodside Road and White Lion Road / Stanley Hill mini-roundabouts that are located either side of the Chiltern mainline and Metropolitan Underground railway lines. This junction provides access to Little Chalfont, Rickmansworth, Watford and Junction 18 of the M25 to the east and Chesham to the north-west. To the south- west the A413 can be accessed which routes north-west to Aylesbury and south-east to Uxbridge and also provides access via the A355 to Junction 2 of the M40.

2.8. To the north of the site Quill Hall Lane remains adopted to its junction with Park Road after which it becomes a private road until just past its junction with Springett Place (as shown on the public highway records obtained from Buckinghamshire County Council and reproduced in Appendix C). Photograph 2.2 records the change in status of Quill Hall Lane.

Photograph 2.2: Quill Hall Lane at the eastern junction of Park Road

2.9. The adopted Park Road continues north and re-joins Quill Hall Lane which continues west and becomes Chestnut Lane providing access to Amersham town centre via Sycamore Road to the south and Chesham via Bois Lane to the north.

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Walking and Cycling 2.10. The physical landscape of northern Amersham is conducive to walking and cycling being relatively level.

2.11. Roads within this area are provided with footways which creates a highly permeable environment and allows safe travel by foot. There are also a number of public rights of way within the vicinity of the site, with footpaths routing directly south towards Amersham Town Centre and the train station as well as areas of employment to the east. These public rights of way are highlighted on Figure 2.1. Footpath AMS/48/1 adjoins the western boundary of the site providing direct access to Quill Hall Lane to the south and open countryside to the north.

Figure 2.1: Public Footpaths & Cycle Routes

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2.12. There are a number of cycle routes within Amersham and these are highlighted in Figure 2.1 with the majority being on-road although some are traffic free routes. The main route through Amersham is Regional Cycle Route (RCR) 30 which routes between Wendover and Chorleywood, via Chesham. At Chesham, National Cycle Route (NCR) 57 routes west through Great Missenden, Princes Risborough and Thames to Oxford.

2.13. RCR30 routes along New Road, approximately 500m to the south west of the site centroid and can be used to access Chalfont and Latimer Underground station. As well as RCR 30, there are a number of local cycle routes with the nearest section of the local routes passing along Quill Hall Lane, past the proposed site access (Harding Route). These localised routes provide links to Amersham Old Town, via the Tesco supermarket (Milton Route).

Public Transport 2.14. The provision of attractive public transport services will allow opportunities for sustainable travel over longer distances and the site is currently accessible to public transport, as described below.

Local Bus Services 2.15. Figure 2.2 shows the existing regular bus services in the vicinity of the site.

2.16. The nearest bus stops are located on New Road and Grove Road, both of which are approximately 500m walking distance from the site centroid. However, these stops only serve routes 71/73 which operate infrequently and do not provide extensive travel options.

2.17. The nearest bus stops which provide access to frequent bus services are located on Woodside Road, approximately 1.25km to the south of the site, equivalent to a 15 minute walk. These bus services are listed in Table 2.1.

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Figure 2.2: Bus Routes

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Table 2.1: Summary of Bus Services in the vicinity of the site Approximate Frequency Service Route Days First Frequency Last Service (Daytime) Service Mon- 06:11 60 mins 18:00 High Wycombe – Amersham – Fri Rickmansworth – Watford Sat 07:25 60 mins 17:19 Sun n/a n/a n/a 336/X336 Mon- 07:23 60 mins 19:26 Watford – Rickmansworth – Fri Amersham – High Wycombe Sat 07:45 60 mins 18:46 Sun n/a n/a n/a Mon- 06:08 15 mins 23:04 High Wycombe – Amersham – Fri Chesham Sat 07:02 15 mins 23:04 Sun 08:58 60 mins 17:56 1 Mon- 06:13 15 mins 23:39 Chesham – Amersham – High Fri Wycombe Sat 07:03 15 mins 23:39 Sun 09:28 60 mins 16:26 Mon- 07:35 5 services 16:04 Amersham – Gerrards Cross – Slough Fri Sat 07:29 1 service 07:29 Amersham – Bovingdon – Hemel Sun 12:09 4 services 18:09 Hempstead 353 Mon- 09:38 5 services 18:00 Slough – Gerrards Cross – Amersham Fri Sat n/a n/a n/a Hemel Hempstead – Bovingdon – Sun 12:04 4 services 18:04 Amersham Mon- 06:05 60 mins 19:52 Uxbridge – Amersham – Hemel Fri Hempstead Sat 07:20 60 mins 19:13 Sun n/a n/a n/a 730 Mon- 05:44 60 mins 19:45 Hemel Hempstead – Amersham – Fri Uxbridge Sat 07:03 60 mins 19:46 Sun n/a n/a n/a Mon- 07:18 7 services 20:27 Fri Aylesbury – Amersham – Chesham Sat n/a n/a n/a Sun n/a n/a n/a 55 Mon- 07:38 7 services 21:08 Fri Chesham – Amersham – Aylesbury Sat n/a n/a n/a Sun n/a n/a n/a Mon- 08:05 60 mins 16:48 Fri 71/73 Chesham – Amersham Sat 10:15 5 services 17:15 Sun n/a n/a n/a

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Approximate Frequency Service Route Days First Frequency Last Service (Daytime) Service Mon- 08:32 60 mins 17:40 Fri Amersham – Chesham Sat 10:45 4 services 16:45 Sun n/a n/a n/a Note: Information taken from travelinesoutheast.org.uk, February 2016.

Rail Services 2.18. The nearest rail station to the site is at Amersham, serving both Chiltern mainline services and London Metropolitan Underground services. It is located approximately 2km (25 minute walk / 8 minute cycle) from the site and can be accessed via bus services operating closer to the site, due to it being located on the main bus corridor operating through Amersham.

2.19. There is also an London Underground station approximately 3.8km east of the site in Little Chalfont (a 13 minute cycle journey time), which operates services twice as frequently due to the joining of services from Amersham and Chesham. This rail station can be reached via bus services 336/X336 and 71/73 and also provides a large number of parking spaces for cars and bicycles.

2.20. Table 2.2 provides a summary of the main weekday rail services available from Amersham Rail Station and Amersham Underground Station.

Table 2.2: Summary of Rail Services from Amersham Rail Station & Amersham Underground Station Train Route Weekday Frequency Operator Morning Peak Evening Peak Daytime (07:00-10:00) (16:00-19:00) Amersham Rail Station Chiltern Aylesbury – Amersham – 20 mins 30 mins 30 mins Railways London Marylebone London Marylebone– 30 mins 30 mins 30 mins Amersham – Aylesbury Amersham Underground Station London Amersham – Kings Cross 15 mins 30 mins 30 mins Underground 30 mins 30 mins 30 mins

2.21. Approximate mainline rail journey travel times to key destinations are as follows:-

. London Marylebone - 35 mins; . Kings Cross - 55 mins; and . Aylesbury - 30 mins.

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3. SUSTAINABILITY

3.1. A review of the local services and facilities that residents and occupiers of the site may wish to utilise on a regular basis and the ability to access such services and facilities by walking, cycling and public transport is provided in this section.

3.2. Chiltern and South Bucks District Councils instructed Lepus Consulting to undertake a Sustainability Appraisal of the Local Plan and a review of the findings reported in the document ‘Sustainability Appraisal of the Chiltern and South Bucks Local Plan Initial Consultation (regulation 18) Incorporating Issues and Options, January 2016’ has been completed in the context of the proposed development.

Local Facilities 3.3. Figure 3.1 illustrates the general location of the site in relation to everyday services and facilities that those living/working at the proposed development may wish to access. A range of services are available within reasonable walking and/or cycling distance of the proposed site and approximate distances are recorded in Table 3.1.

3.4. ‘Manual for Streets’, March 2007, states that walkable neighbourhoods are typically characterised by having a range of facilities within 10 minutes' (up to about 800m) walking distance. The Institution of Highways and Transportation's (IHT) document 'Providing for Journeys on Foot' sets out preferred walking distances to key facilities. It identifies maximum preferred walking distances of 2km for commuting and 1.2km for other purposes. The 2km isochrone as measured from the centroid of the site is shown in Figure 3.2.

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Figure 3.1: Local Facilities

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Table 3.1: Local Facilities and Journey Times Approximate Walking Cycling Time Facility Description Distance (m) Time (mins) (mins) Healthcare* Pharmacy – 1,800 22 6 Superdrug, Sycamore Road Amersham Health Centre, 1,960 24 7 Chiltern Avenue Amersham Hospital, 4,050 49 14 Whieldon Street Education Primary School 1,270 16 5 Chestnut Lane School Primary School 1,130 14 4 Woodside Junior School Secondary School Dr Challoners Grammar School, 2,210 27 8 Chesham Road Secondary School The Amersham School, 2,000 24 7 Stanley Hill Food Retail Little Waitrose 1,840 22 7 Sycamore Road Tesco Supermarket 3,730 45 13 London Road West Retail/Business Amersham Town Centre 1,800 22 6 Sycamore Road Post Office 2,170 26 7 Sycamore Place Cashpoint (ATM) 1,750 21 6 Woodside Road Employment Corinium Industrial Estate – 1,000 12 4 Raans Road Plantation Road 1,270 16 5

Leisure The Chiltern Pools – Chiltern 1,820 22 7 Avenue Amersham Hill Cricket Club – 1,320 16 5 Peter Dwight Drive Transport Amersham 2,220 27 8 Railway/Underground Station Bus Stops – Woodside Road 1,520 19 6 * Proposed development includes a doctor’s surgery Note: Distance is the walking distance from the centre of the site measured along existing roads and footpaths. Journey times have been rounded up to nearest whole minute.

Education 3.5. The nearest primary schools to the site are Woodside Junior, approximately 1.1km to the south and Chestnut Lane located 1.25km to the west. These schools are approximately a 15 minute walk or 5 minute cycle from the site. The nearest mixed secondary school (11 – 18) is The Amersham School located on Stanley Hill approximately 2km to the south of the site (24 minute walk or 7 minute cycle). Dr Challoners’s Grammar School is located 2.2km to the south-west of the site and can provide education for boys aged 11 – 18 years old.

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Figure 3.2: 2 km Isochrone from Site Centroid

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Employment 3.6. The nearest area of major employment is the Corinium Industrial Estate, located on Raans Road approximately 1km to the south of the proposed site or a 12 minute walk or a 4 minute cycle. There are also a number of high street retailers and services within Amersham Town Centre located approximately 1.8km to the south of the site, approximately a 22 minute walk or 6 minute cycle.

Health 3.7. The nearest current health centre is Amersham Health Centre located off Chiltern Avenue approximately 1.95km to the south of the site. However, the proposed development includes a new doctor’s surgery and therefore all future residents will be located within a short distance of a GP unit. The Amersham Hospital is located approximately 4km to the south of the site. Visitors can access the hospital via bicycle (14 mins) or by public transport (services 1, 55 and 71/73). The hospital provides approximately 50,000 outpatient appointments per annum, a neurorehabilitation centre and is Buckinghamshire Healthcare’s main base for the care of the elderly.

Leisure 3.8. There are a number of leisure options to the south within and around the centre of Amersham. The nearest leisure centre is located approximately 1.8km to the south on Chiltern Avenue and is a 22 minute walk or 7 minutes by cycle. The centre offers a gym, fitness classes, a 25 metre swimming pool, a leisure pool with flumes, a climbing wall and a MUGA pitch for 5-a-side football. In addition Amersham Cricket Club is located on Peter Dwight Drive, approximately 1.3km south of the site, a 16 minute walk or 5 minutes by cycle.

Food Retail 3.9. Within Amersham town centre there are a number of food retailers offering smaller convenience food retail in the forms of M&S Foodhall and Little Waitrose, both located approximately 1.8km to the south and a 22 minute walk or 7 minute cycle. There is also a large Tesco Superstore approximately 3.7km to the south of the site which is reachable in under 13 minutes by cycle or by bus services 1, 55, 71/73 and (X)336.

Summary 3.10. The above assessment demonstrates that the site is located within suitable walking and/or cycling distance of a large number of everyday services and facilities. The site is not currently well served by bus public transport with walk distances to frequent bus services and Amersham railway stations in excess of recommended distances However, the cycling distances to the Amersham railway station and the majority of other facilities are a short distance for cyclists.

Sustainability Appraisal of the Chiltern and South Bucks Local Plan Initial Consultation (Regulation 18) Incorporating Issues and Options: Lepus Consulting – January 2016 3.11. The Sustainability Appraisal completed by Lepus Consulting presents the results of an assessment of reasonable alternatives for housing and employment sites in the Chiltern and South Bucks area to help inform the Councils’ preparation of their joint Local Plan.

3.12. The development site ‘Market Reading Field’ forms part of the site identified within the document as ‘Amersham 1’.

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3.13. There are two objectives identified and assessed that relate directly to sustainability in terms of transportation and access by modes other than the private car.

3.14. Objective 9: Transport Assumptions, uses the recommended distances of 400m to a bus stop and 1,000m to a train station (based on 800m for tram) identified within the Barton et al document ‘Shaping Neighbourhoods:2010’.

3.15. With respect to the site notated ‘Amersham 1’, the report states:

“There are no trains within 1km or bus stops within 400m of the site, but public footpaths both pass through and around the site.”

3.16. This is an observation of the current situation and does not provide an analysis of possible mitigation that could be offered.

3.17. It is intended that the proposed development would fund a bus service (mini or midi size) providing direct access to Amersham rail station enabling future residents and employees to access the station via public transport. An initial route for the bus service is shown in Figure 3.3 and would route along Raans Road providing access to the Corinium industrial estate and the proposed housing estate which are not currently on any bus route. Bus stops would be positioned to be within 400m of the route.

Figure 3.3: Initial Route Option for proposed Bus Service

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3.18. Objective 11: Health, uses the target distances and maximum distances to certain facilities and amenities identified in Barton et al as shown in Table 3.2.

Table 3.2: Sustainable distances to facilities and amenities (Barton et al, 2010) Feature Target distance Maximum distance Local park / greenspace 400m 600m Leisure centre 1,500m 2,000m Doctor’s surgery 800m 1,000m Hospital 5,000m 8,000m

3.19. With respect to the site ‘Amersham 1’, the report states:

“There are no areas of public greenspace within 600m of the site, although the Chiltern Pools Leisure centre offers opportunities for recreation within 2km. Amersham Hospital is within 5km of the site, although the nearest doctor’s surgery is over 1km away.”

3.20. This document has only assessed four of the facilities/amenities identified within Barton et al and again is an observation based on the current situation without knowledge of the quantum of development proposed on the site.

3.21. It is intended that the proposed development would introduce a large area of green open space together with playspace for children within the site and therefore the Objective 11 access will be within the target distance of 400 metres. The proposed development also intends to include a doctor’s surgery and therefore access will be within the target distance of 800 metres for all new residents / employees. In addition, access to the surgery for existing residents in north-east Amersham will be enhanced.

3.22. It should also be noted that the Lepus Consulting report incorrectly identifies that the Amersham and Chalfont & Latimer railway stations are within 1 km of site ‘Amersham 2’ and that the Amersham railway station is within 1km of site ‘Amersham 3’. The distances measured ‘as the crow flies’ are 1.13km and 3km respectively for ‘Amersham 2’ and 1.16km for ‘Amersham 3’.

Summary 3.23. The Sustainability Appraisal undertaken by Lepus Consulting indicates that the site does not meet the access criteria in terms of transport and health. However, the assessment was undertaken without consideration of the type of proposed development and mitigation measures. It is intended to include green open space, childrens’ playspace and a doctor’s surgery all of which would be accessible and meet Objectives 9 and 11.

Census Data 3.24. Analysis of the travel to work mode from the 2011 national census (residents aged 16 – 74) has been undertaken for the following wards:

. Amersham-on-the-Hill (E05002631) . Chesham Bois and Weedon Hill (E05002640)

3.25. These wards cover both the southern and western sections around the site and the local residential areas in north and central / east Amersham. Figure 3.4 shows the ward areas.

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Figure 3.4: Ward Boundary Map

3.26. Table 3.3 details a summary of the Census results.

Table 3.3: Census 2011 Travel to Work Mode Chesham Amersham- % by Bois and Modal Travel to Work Mode on-the-Hill Combined Underground Weedon Hill Share (%) (E05002631) / train (E05002640) Underground, metro, light 233 276 509 12% rail, tram 24% Train 227 254 481 12% Bus, minibus or coach 62 24 86 2%

Taxi 13 7 20 0%

Motorcycle, scooter or 15 10 25 1% moped Driving a car or van 1,156 1,172 2,328 56%

Passenger in a car or van 104 67 171 4%

Bicycle 42 23 65 2%

On foot 274 167 441 11%

Other method of travel to 20 18 38 1% work

3.27. The analysis shows that a quarter of all residents rely on the London Underground and railway network for their journey to work. This shows the importance of good access to these modes of transport for residential development in Amersham.

Mitigation 3.28. To increase sustainability, in terms of access to local facilities by modes of transport other than the private car, the development proposes to:

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. Introduce 625m2 gfa of B1(a) or B1(b) use;

. Include a doctor’s surgery;

. Introduce greenspace and a children’s play area;

. Provide a permeable walking development with links to the existing walking network both urban and rural;

. Introduce a circular bus service (mini or midi-bus) to provide access for residents to the Corinium Industrial Estate, the town centre and Amersham mainline rail and Underground stations; and

. Introduce a Travel Plan to encourage travel by sustainable modes of transport rather than single occupancy car.

Summary & Conclusion 3.29. Paragraph 17 of the National Planning Policy Framework (NPPF) sets out 12 core land-use planning principles. One of these core principles is to actively manage patterns of growth to make the fullest use of public transport, walking and cycling, focusing significant development in locations which are, or can be made sustainable.

3.30. The proposed development site is located on the edge of an existing town offering future residents the ability to access existing services and facilities. The sustainability assessment has shown that many of these services and facilities are within comfortable walking and/or cycling distances of the site and further with the bus service proposed the proposed development would meet the travel sustainability principle of Paragraph 17 of the NPPF. In addition to residential development the proposed development would deliver employment, a doctor’s surgery and green space for the benefit of future residents and existing residents in the locality.

3.31. The development layout will offer a permeable walking and cycling network with links to the existing cycling and walking network offering access to existing services and facilities and the countryside.

3.32. The site is located approximately 2km from Amersham railway station and 1.5km from a frequent bus service. To improve access to these public transport modes, in particular access to the mainline rail and London Underground, it is intended that a bus service on a circular route (mini or midi-bus) would be introduced as part of the proposed development. Given the significant proportion of existing residents that travel to work by either mainline rail or the Underground such a local bus service should be a welcome addition.

3.33. Overall, given the location of the site and the mitigation proposed it is concluded that the proposed development would meet the core planning principle of transport sustainability set out in the NPPF.

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4. ACCESS FEASIBILITY Introduction 4.1. Paragraph 32 of the NPPF states:

“Plans and decisions should take account of whether:

 Safe and suitable access to the site can be achieved by all people”

4.2. This section provides describes the points of access by vehicles, pedestrians and cyclists. It will also provide expected vehicle trip generation and an overview of the impact of the proposed development on local key junctions.

Proposed Vehicular Access 4.3. Due to the location of the site, adjacent to a railway line on its eastern boundary and fields on its western boundary, vehicular access is only feasible from the south. The southern boundary consists of housing which currently represents the extent of the built environment.

4.4. The landowner of the site controls the land between the site boundary and the end of Eagle Close. Photograph 4.1 shows this land looking north from Eagle Close and Photograph 4.2 shows a reverse view from within the site.

Photograph 4.1: Site Access looking North from Eagle Close

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Photograph 4.2: Site Access looking South from within the site

4.5. As described in section two, Eagle Close is an adopted highway, with a 5.5m width carriageway and a single footway. Exit visibility at its junction with Quill Hall Lane meets current guidance as set out in the DfT document ‘Manual for Streets’ (MfS). MfS identifies this width of road as being able to accommodate two large vehicles passing one another at slow speed on straight stretches of carriageway. MfS also states that carriageway widths should be appropriate for the particular context and use of the street with key factors to be taken into account to include volume of vehicular traffic, pedestrian activity, traffic composition, on-street parking, design speed and the curvature of the street.

4.6. The proposed vehicular access from Eagle Close will require traffic to negotiate a 90o bend and swept path analysis has been undertaken to check that expected typical vehicle movements could be accommodated. The vehicle tracking is shown on PFA Drawing No. L409/1 reproduced in Appendix D and indicates that widening of the bend to accommodate the expected vehicle types should be carried out.

4.7. The drawing also indicates that the required forward visibility (25 metres for vehicle speeds of 20mph which is in accordance with the guidance of MfS) can be provided within the land under the control of the proposed developer.

4.8. In the unlikely event that the proposed single point of vehicular access was blocked, a potential emergency access is available via the track from Quill Hall Lane which serves the properties of Highbrow, Silver Birches, Ridge House, Penn Lodge and Chiltern Cottage. This track is within the ownership of the proposed developer. The location of the potential emergency access is shown on the indicative masterplan reproduced in Appendix A.

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Proposed Pedestrian and Cycle Access 4.9. The potential emergency access would also provide a pedestrian and cycle access from the site directly to Quill Hall Lane.

4.10. The footway of Eagle Close would provide an additional pedestrian access from the site.

4.11. Finally, two points of access would be provided onto the public footway on the western boundary of the site, enabling pedestrian access onto Quill Hall Lane to the south and the countryside to the north. These points of access are shown on the masterplan reproduced at Appendix A.

Trip Generation 4.12. Vehicular trip generation has been predicted for the proposed development using trip rates obtained from the national database Trip Rate Information Computer System (TRICS 7.2.2).

4.13. Weekday surveys were selected along with ‘Edge of Town’ and ‘Suburban Area’ locations. With respect to ‘Houses Privately Owned’ only surveys from the southern regions were used. This geographic selection could not be used for the other Use Classes due to the small number of surveys. The vehicular trip rates are shown in Table 4.1.

Table 4.1: TRICS Vehicular Trip Generation Rates Arrivals Departures Total Privately Owned Dwellings (per dwelling) 08:00-09:00 0.165 0.477 0.642 17:00-18:00 0.436 0.240 0.676 Affordable Dwellings (per dwelling) 08:00-09:00 0.109 0.207 0.316 17:00-18:00 0.215 0.157 0.372 Employment (per 100m2) 08:00-09:00 1.489 0.265 1.754 17:00-18:00 0.190 1.271 1.461 GP Surgery (per consulting room) 08:00-09:00 5.076 2.439 7.515 17:00-18:00 2.091 3.303 5.394

4.14. The proposed development would be mixed-use consisting of approximately 60 dwellings (with 40% affordable), 625m2 gfa of B1(a) / B1(b) in the form of units no greater than 125m2 and a doctor’s surgery (assumed 5 GPs). The trip generation for each use and the overall total trip generation is shown in Table 4.2 below.

21 of 24 L409-DOC01 March 2016 Page 46 of 104 Classification: OFFICIAL PORep1510 (REDACTED) MARKET READING FIELD, AMERSHAM TRANSPORT SUSTAINABILITY & ACCESS FEASIBILITY STUDY

Table 4.2: Estimated Vehicular Trip Generation Arrivals Departures Total Privately Owned Dwellings (36 dwellings) 08:00-09:00 6 17 23 17:00-18:00 16 9 24 Affordable Dwellings (24 dwellings) 08:00-09:00 3 5 8 17:00-18:00 5 4 9 Employment (650m2) 08:00-09:00 10 2 11 17:00-18:00 1 8 9 GP Surgery (5 consulting rooms) 08:00-09:00 25 12 38 17:00-18:00 10 17 27 TOTAL 08:00-09:00 44 36 80 17:00-18:00 32 38 69

4.15. The quantum of vehicle movements equates to an average of an additional vehicle every 45 seconds in the AM peak hour and every 52 seconds in the PM peak hour. Eagle Close and the junction of Eagle Close with Quill Hall Lane are considered to be suitable to accommodate this level of additional vehicle movements.

4.16. Due to the network of adopted roads in the vicinity of the site, the majority of vehicle movements by the proposed development would travel south along Quill Hall Lane, along Raans Road and through the Raans Road / Woodside Road and White Lion Road / Stanley Hill mini-roundabouts.

4.17. On site observations of these junctions during peak periods indicates that traffic queues on the Woodside Road arm which also affects the Woodside Road / Plantation Road junction. The functioning of this junction is important to the flow of traffic within and through Amersham and at the time of a planning application detailed assessment of the operation of this key junction would need to be modelled to identify the significance of the effect of development related traffic.

Summary & Conclusion 4.18. A safe and suitable access can be provided for all users of the development in accordance with the requirements of the NPPF.

4.19. The expected two-way vehicle trip generation of the proposed development is predicted to be approximately 80 trips in the AM peak hour and approximately 70 trips in the PM peak hour. Whilst subject to further assessment, Eagle Close and the Eagle Close / Quill Hall Lane junction are considered able to accommodate this level of development related traffic.

4.20. It is anticipated that the majority of traffic generated by the proposed development would travel through the Raans Road / Woodside Road and White Lion Road / Stanley Hill mini-roundabouts where queuing has been observed on the Woodside Road arm. These junctions would be

22 of 24 L409-DOC01 March 2016 Page 47 of 104 Classification: OFFICIAL PORep1510 (REDACTED) MARKET READING FIELD, AMERSHAM TRANSPORT SUSTAINABILITY & ACCESS FEASIBILITY STUDY

assessed to determine the significance of the effect of development related traffic as part of a Transport Assessment to accompany a planning application.

23 of 24 L409-DOC01 March 2016 Page 48 of 104 Classification: OFFICIAL PORep1510 (REDACTED) MARKET READING FIELD, AMERSHAM TRANSPORT SUSTAINABILITY & ACCESS FEASIBILITY STUDY

5. SUMMARY AND CONCLUSIONS

5.1. This Transport Sustainability & Access Feasibility Study has been prepared by PFA Consulting on behalf of The Trustees of Market Reading Field to support representations to Chiltern District Council and South Bucks District Council in respect of the initial Issues & Options consultation being undertaken as part of the emerging joint Chiltern and South Bucks Local Plan (2014-2036).

5.2. The proposed development site is known as Market Reading Field (identified as site CD0046 in the Chiltern District & South Bucks District ‘Draft Housing & Economic Land Availability Assessment’: January 2016).

5.3. The proposed development site is located on the edge of an existing town offering future residents the ability to access existing services and facilities. The sustainability assessment has shown that many of these services and facilities are within comfortable walking and/or cycling distances of the site and further with the bus service proposed the proposed development would meet the travel sustainability principle of Paragraph 17 of the NPPF. In addition to residential development the proposed development would deliver employment, a doctor's surgery and green space for the benefit of future residents and existing residents in the locality.

5.4. The development layout will offer a permeable walking and cycling network with links to the existing cycling and walking network offering access to existing services and facilities and the countryside.

5.5. The site is located approximately 2km from Amersham railway station and 1.5km from a frequent bus service. To improve access to these public transport modes, in particular access to the mainline rail and London Underground, it is intended that a bus service on a circular route (mini or midi-bus) would be introduced as part of the proposed development. Given the significant proportion of existing residents that travel to work by either mainline rail or the Underground such a local bus service should be a welcome addition.

5.6. Overall, given the location of the site and the mitigation proposed it is concluded that the proposed development would meet the core planning principle of transport sustainability set out in the NPPF.

5.7. A safe and suitable access can be provided for all users of the development in accordance with the requirements of the NPPF.

24 of 24 L409-DOC01 March 2016 Page 49 of 104 Classification: OFFICIAL PORep1510 (REDACTED)

Woodland Trust

20m existing tree belt

Page 50 of 104 N Scale 1:500 0m Classification: OFFICIAL 10m 20m

30m 2.4 x 43m visibility splay visibility 43m x 2.4 40m

50m 2.4 x 43m visibility splay visibility 43m x 2.4 PORep1510 (REDACTED) e aeDescription Date Rev File Ref. E-Mail Checked By Drawn By Scale Date Drawing No. Drawing Title Project Client Junction of Eagle Close Market Reading Field Leywood Estates Ltd with Quill Hall Lane Visibility Splays at Stratton Park House, Wanborough Road Amersham Page 51 of 104 L409_3.dwg [email protected] AW TLH 1:500 @ A4 09/03/16 L409/3 [email protected] Swindon, SN3 4HG www.pfaplc.com 01793 835500 01793 828000 Telephone Facsimile Website Email ntasCheck Initials

Def 84 Classification: OFFICIAL PORep1510 (REDACTED)

10 The

Path (um) Cottage Sluice El Sub Sta The 87.8m Bungalow

Path (um) 11 Blackwell Stubbs

142.0m

8 16 FB

Cop per field 15

Path (um)

14 Bois Mill FB 12

17 18 1 1a ED & Ward Bdy

2 LATIMER ROAD 20 M P 2 WOODSIDE AVENUE

Post 19

7 20a

22 44

10 21

43 Chesham Bois 24

STUBB S WOOD ED & Ward Bdy

23 24a

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36

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MILTON LAWNS WOODSIDE AVENUE 33 30

Path (um) 41

23 FF

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37

1

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The Oaks Pupil

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8

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27 34 40

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QUILL HALL LANE

RIGHTS OF WAY COMMON LAND AND VILLAGE GREENS The Rights of Way information on this plan is based on information The Common Land and Village Green information on this plan from The Definitive Map of Public Rights of Way in Buckinghamshire ("The Definitive Map"). is based on information from the Common Land and Village 1:4,000 ± Accuracy of this plan cannot be guaranteed. If in doubt, The Definitive Map should be consulted. Green Register ("The Register") held by Buckinghamshire Page 52 of 104 County Council. Accuracy of this plan cannot be guaranteed. © Crown Copyright. All rights reserved. Buckinghamshire County Council Licence No. 100021529 2008. If in doubt, The Regiser should be consulted. Classification: OFFICIAL PORep1510 (REDACTED)

N

Stratton Park House, Wanborough Road Swindon, SN3 4HG

Telephone 01793 828000 Facsimile 01793 835500 Email [email protected] Website www.pfaplc.com

9.19

1.785 3.03 1.22

Olympus 6x4 Wide Overall Length 9.190m Overall Width 2.530m 25m forward visibility for 20mph Overall Body Height 3.211m Min Body Ground Clearance 0.416m Track Width 2.530m Lock to Lock Time 4.00s Kerb to Kerb Turning Radius 7.800m

5.885

0.72 3.7

R19m 4.6t Light Van Overall Length 5.885m Overall Width 2.000m Overall Body Height 2.526m Min Body Ground Clearance 0.299m 6.5m Track Width 1.765m Lock to Lock Time 4.00s Kerb to Kerb Turning Radius 6.000m

Rev Date Description Initials Check Status PRELIMINARY

Client

Leywood Developments Ltd

Project

Market Reading Field

Drawing Title

Extension of Eagle Close

Drawing No. 0m 10m 20m 30m 40m 50m L409/1 Date March 2016 Scale 1:500 @ A3 Scale 1:500 Drawn By PJ Checked By PT E-Mail [email protected] File Ref. F:\Workfile\L409\Drawings\L409_1

Page 53 of 104

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C Client Status t Notes / Revisions ec

X it TRUSTEES OF MARKET READING FIELD MARKET READING FIELD h a david parker c

CONSULTATION r

o The Old Brewery Tap Tel: 01491 613066 A Drawing Title Dwg N Rev Project r e

3 Shirburn Street Fax: 01491 614017 k r

SITE LOCATION a

Watlington Email:[email protected] P

d MASTERPLAN i Oxfordshire OX49 5BU Web:www.dparchitects.co.uk Drawn By Scale Date 16 MRF SL1 - v

RIBA a dp

architects XX.XX.XX D Chartered Practice ML 1:5000 @ A3 25.02.16 Page 54 of 104 C Only to be scaled from for planning and land registry purposes. All figured dimensions are millimetres unless otherwise stated. Contractors must verify all dimensions before starting work and any discrepancies are to be reported to David Parker Architects Ltd.This drawing is the property of David Parker Architects Ltd. Copyright is reserved by them and is issued on the condition that it is not copied or disclosed by or to any unauthorised persons without the prior consent in writing by David Parker Architects Ltd. Classification: OFFICIAL PORep1510 (REDACTED)

WoodlandTrust

20mexisting tree belt tree

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Views from adjoining footpath showing Quill Hall Farm as part of an extension to the adjoining countryside. Note Metropolitan Line is no longer in a cutting.

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of built form and strong visual connection with the surrounding countryside. A sense of openness is partially diminished in the north of the land parcel by the physical severance of the land parcel and the surrounding countryside by the railway line. However, overall the land parcel has a strong unspoilt rural character.”

2.30 Market Reading Field is not characterised by fields, but comprises an area of scrubland which is not in agricultural use, and where all of its boundaries are delineated by dense deciduous and coniferous tree planting. Market Reading Field is not seen either from within the site or from positions outside the same parcel of land as having steep slopes characteristic of the landscape of this part of Chiltern District, and more particularly it does not display or possess any strong sense of openness or visual connection with the surrounding countryside.

2.31 It represents an enclosed parcel of land, with no sense of openness save for that experienced within the field itself culminating in its well screened mature boundaries. It is severed from the surrounding countryside by the Metropolitan railway line, and does not display a strong unspoilt rural character. On the contrary, Market Reading Field is seen more as possessing a semi-urban character, highlighted by a network of worn tracks where unauthorised or illegal access has been gained by members of the public for recreational purposes, a factor which has necessitated signage being erected by the owners of the site highlighting the fact that the land is in private ownership prohibiting entry.

2.32 In this way, and even if it is contended, contrary to the writer’s view, that Market Reading Field possesses a largely rural open character, it should reflect a score of either 2 or 3 in accordance with Purpose 3, in that the same land cannot be said to reflect “a strong unspoilt rural character”, characterised by rural land uses and landscapes, as portrayed by Quill Hall Farm.

2.33 Table 1 overleaf is a re-appraisal of Market Reading Field independent of Quill Hall Farm as part of General Area 22b, particularly when seen from Purpose 1b and 3 taken from the Buckinghamshire Green Belt Assessment Part 1A: Methodology. A comparison of the results with other land parcels comprising General Areas situated on the built-up edges of Amersham found overleaf, and recommended for

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further consideration as suitable candidates for built area extension options around the same settlement; leads to the following conclusions.

A. Market Reading Field scores equally in respect of Green Belt Purposes 1b and 3 with General Area 23a, but better on the remaining two Purposes 2 & 4 with the same parcel. In this respect it is noted that part of General Area 23a has been recommended for further consideration, but the same exercise has not been extended to General Area 22b, in the event of Quill Hall Farm being excluded. To the extent that the results reveal that a portion of General Area 23a is considered a suitable candidate for further consideration, so too should the same conclusion be reached in assessing Market Reading Field independently from Quill Hall Farm.

B. Market Reading Field when compared with General Area 23b, scores identically with Purpose 3; better in its score concerning Purpose 4, but less favourably in respect of Purposes 1b and 2. However, General Area 23b comprises a parcel of land which is almost double the size of Market Reading Field, and hence is likely, in all probability, to have a greater overall impact on Green Belt purposes. The potential release of all of the land forming part of General Area 23b, when seen in terms of the size of the built up area of Amersham is of a scale which is not proportionate to that of the main town it borders. This is a matter evident from the Drawing showing all the various parcels of land around Amersham found at page 27 of these representations.

C. An identical result to that set out in B. above arises from a comparison of General Area 22b, excluding Quill Hall Farm, with General Area 30. The whole parcel comprising General Area 30 is recommended for further consideration, being of a size comparable to that of Market Reading Field.

D. A similar conclusion arises when comparing General Area 22b, excluding Quill Hall Farm, with General Area 31, although this is of a smaller size than Market Reading Field and is unlikely to satisfy all of the development

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needs performed by the small mixed use SUE extension to Amersham comprising Market Reading Field. 2.34 Table 2 overleaf is a plan showing the various general areas in Chiltern District Council and South Bucks District Council administrative areas, with those parcels diagonally hatched in red being recommended for further consideration as suitable candidate for further extensions, alongside the area in solid red comprising that part of General Area 22b known as Market Reading Field.

IV. Considerations Surrounding the Sustainability Appraisal Associated with the Release of Market Reading Field

E. Pre-Mitigation Sustainability Appraisal of Market Reading Field Comprising Part of the “Amersham 1 Area of Search” Relating to a Housing Led Development

2.35 In the Sustainability Appraisal prepared by Lepus Consulting dated January 2016 the land shown as a built area extension option comprising both Quill Hall Farm and Market Reading Field on the north eastern side of Amersham is referred to as “Amersham 1 Area of Search”, with the entire site assessed against 12 separate sustainability objectives.

2.36 In examining Market Reading Field independently from the rest of the “Amersham 1 Area of Search”, reveals that the site is not close to any listed buildings and no archaeological notification sites would be lost (SA Objective 1).

2.37 Market Reading Field is situated in the Chilterns AONB which will result in a change to the landscape character of the area. It is situated in the Hyde Heath Settled Plateau, described by Land Use Consultants in their Buckinghamshire Landscape Character Assessment (2011) in the following terms.

“A flat plateau landscape with a strong sense of openness. Large arable fields dominate, and demonstrate a clear geometric form delineated by a good network of hedgerows, which create visual unity. Small areas of woodland are interspersed, largely concentrated along the edges of the character area and consistent with the high slopes of adjacent valleys. Elsewhere tree cover is relatively sparse. Prominent settlement areas are located at Amersham, Hyde Heath and South Heath, displaying a distinctive historic core, with more modern development edge. Small clusters of buildings and individual farmsteads are dispersed throughout. Rural roads wind through the landscape, with the exception of the B485, which cuts through the north of the area, and is traversed by a high voltage pylon line, creating a localised highly visible vertical feature in this open ______27 Classification: OFFICIAL Page 61 of 104 Classification: OFFICIAL PORep1510 (REDACTED)

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landscape. Away from the road, a strong sense of tranquillity prevails. This is a highly legible landscape, with long views across fields, and occasional glimpses out across adjacent valleys. “

TABLE 2

General Areas Recommended by Ove Arup & Partners for Future Consideration as Suitable Candidates for Built Area Extension Options Including the Land Known as Market Reading Field

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Views looking north westwards towards Quill Hall Farm and Metropolitan line in a cutting delineating the north eastern boundary of Market Reading Field.

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Views from adjoining byway over Quill Hall Farm depicting its relationship with the surrounding open countryside

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2.38 This is a generic description, which is inconsistent with what is depicted at Market Reading Field, as a site visit will confirm. This landscape description is not commensurate with the photographic evidence set out earlier in these representations. Whilst Market Reading Field comprises a predominantly flat plateau landscape, it does not possess a strong sense of openness delineated by a network of hedgerows possessing a geometric form. More particularly it represents a contained parcel of land, with well screened woodland edges where there are no glimpses over adjacent valleys, which in this case would form part of the Chess Chalk River Valley Character Area. It follows that there is a markedly different landscape character displayed by Market Reading Field from that expressed by Quill Hall Farm, which is more representative of the generic description relating to the Hyde Heath Settled Plateau Landscape Character Area.

2.39 Lepus Consulting in paragraph 3.1.2 of their Sustainability Appraisal emphasise the inter-visibility, namely long views across fields and occasional views towards Misbourne Valley and Chess Valley, experienced from the “Amersham 1 Area of Search”. Whilst issues of inter-visibility are relevant when considering the release of land at Quill Hall Farm for future development purposes, they are not pertinent when considering Market Reading Field, where there is no strong sense of openness, and as a result, an absence of distant views, due to the strong screening effect of trees along all of its boundaries. It follows that a development within Market Reading Field of a form set out in the Masterplan prepared by dparchitects would not detract from those features representative of the landscape character provided by the Hyde Heath Settlement Plateau or the Chess Chalk River Valley Character Areas (SA Objective 2).

2.40 There is no evidence of protected species being present on the land known as Market Reading Field, and no biodiversity designations concerning the same site. There is an absence of hedgerows, with mixed woodland belts encircling the same land all capable of retention, to the extent that there would be no loss of any habitats. The site contains no buildings which would provide habitats for European Protected Species (SA Objective 3).

2.41 The South Bucks District Transport Strategy (2010) refers to the A355 and A413 which lie in close proximity to the site as being highly congested roads. There are

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no train stations within 1km or bus stops within 400m of Market Reading Field, although a dense network of footpaths, bridleways and cycle routes in the immediate locality, provides important permeability to the same site. It is expected that residents of a proposed housing-led scheme would be dependent on cars for travel, and are likely to commute to larger centres for employment and amenity purposes. This situation may exacerbate congestion in the area, possibly increasing the District’s contribution to climate change (SA Objectives 4 & 9).

2.42 Loss of green infrastructure as a consequence of a housing led development may have negative implications with regard to climate change adaptation, due to the roles that green infrastructure can play in adapting to climate change. The site is located in Flood Zone 1, which is at low risk of flooding (SA Objective 5).

2.43 Additional housing in Amersham may result in increased pressure on capacity at the sewage works which in turn may lead to sewage overflow and water pollution at Maple Lodge, resulting from a lack of capacity (SA Objective 7).

2.44 There are no areas of accessible public green space within 600m of Market Reading Field, although the Chiltern Pools Leisure Centre offers opportunities for recreation within 2km. Amersham Hospital is within 5km of the site, although the nearest doctor’s surgery is over 1km away. These distances are the maximum recommended distances for shaping neighbourhoods for local health and global sustainability as set out in the study prepared by Barton et Al in 2010. A housing- led development of Market Reading Field would lead to a loss of part of the recognised green infrastructure network of Buckinghamshire, and may result in loss of attractive and recreational spaces for residents (SA Objective 11).

2.45 The land owned by the Trustees of Market Reading Field does not comprise best and most versatile agricultural land (SA Objective 6), although much needed open market and affordable housing would be provided in the event that Market Reading Field is developed in the form of a housing led scheme (SA Objective 10). To the extent that a housing led scheme would not involve any loss or gain in employment led development, means that there would be no effect on employment provision (SA Objective 12).

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F. Post Mitigation Sustainable Appraisal of Market Reading Field as a Mixed Use SUE

1. SA Objective 1: Cultural Heritage 2.46 A mixed use SUE on the Market Reading Field site would enable a series of post mitigation benefits to occur in response to negative or uncertain assessment findings associated with the pre-mitigation stage. A scheme of the form and nature indicated in the Masterplan Drawing No. 16 MRF SP1 prepared by dparchitects would result in no harm to, or loss of features of architectural or historic interest, scheduled monuments, registered parks and gardens, or World Heritage Sites. Archaeological sites/ remains would not be harmed by a development of the kind suggested by dparchitects, and neither would the setting of any cultural assets be affected. In this way, irreversible adverse effects where they relate to cultural heritage considerations remain unaffected by the release of Market Reading Field as a small mixed use SUE, with the consequence they do not require any post- mitigation measures.

2. SA Objective 2: Landscape 2.47 The impact arising from the release of land owned by The Trustees of Market Reading Field to meet future development needs in your Authority and South Bucks District Council through the means of a mixed use SUE has been assessed earlier in this chapter. It has been shown that there are exceptional circumstances which have led the respective authorities as part of the forthcoming Local Plan to review Green Belt boundaries. Furthermore, it has been demonstrated in conjunction with the Buckinghamshire Green Belt Assessment Part 1A: Methodology that the land owned by the Trustees of Market Reading Field does not fulfil to any significant extent the five purposes set out in paragraph 80 of the NPPF, whether examined individually or collectively. This factor is considered germane when assessing losses of Green Belt land.

2.48 To the extent that paragraph 115 of the NPPF seeks to afford great weight to conserving landscape and scenic beauty in Areas of Outstanding Natural Beauty, dictates that development in these areas should be kept to a minimum where possible, retaining the distinctive landscape features of designated sites and their settings, and reflecting the patterns and styles of local vernacular.

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2.49 It is a fact that all the land in the areas surrounding the built-up area of Amersham are found in the Chilterns AONB, and with these considerations in mind, development should be carefully designed and include landscape management strategies to reflect the landscape character areas. Light and noise pollution should be minimised, with new development seeking to make use of existing landscape buffer zones to ensure proposals can be assimilated into the local character. These recommendations can be more easily provided given the consistent well screened boundary treatment encircling Market Reading Field.

3. SA Objective 3: Biodiversity 2.50 The MAGIC database has been interrogated, with the result that there are no sites of statutory or non-statutory importance designated for biodiversity or geodiversity interest affecting Market Reading Field, whilst the same land does not form part of a Special Area of Conservation, a Special Protection Area, a National Nature Reserve, a Site of Special Scientific Interest, a Local Nature Reserve or an Area of Ancient Woodland. In this way there will be no net loss in biodiversity, neither will there be a removal of features within the main confines of the same land comprising trees and hedgerows, with the consequence that there will be no likelihood of habitat fragmentation. What is sought will not remove areas of woodland surrounding the site, acting as a strong buffer to built development. The continued presence of an area of land for public open space purposes will help mitigate or compensate habitats lost elsewhere.

4. SA Objective 4: Climate Change Mitigation 2.51 The layout of the proposed development shown on the Masterplan prepared by dparchitects reveals that the site scores highly in terms of its legibility, taking advantage of access points into the site, emphasising pedestrian routes, and allowing a choice of access to public open space which in turn will lead into the open countryside. In this way, the proposed mixed use SUE enhances focal points on identified routes linking the urban fabric of Amersham with the surrounding countryside.

2.52 What is sought will provide increased opportunities to the occupiers of new dwellings on the Market Reading Field site, as well as those residing in adjoining built development, allowing for easy access to services including pedestrian routes

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into open countryside. These are important measures in supporting sustainable transport modes including the provision of a minibus to service this part of Amersham.

2.53 The development is expected to maximise the energy efficiency of buildings contributing to a percentage of energy generated from renewable sources, whilst at the same time contributing to sustainable methods of drainage.

5. SA Objective 5: Climate Change Adaptation 2.54 It is an important remit of the NPPF for Local Planning Authorities to plan positively for the creation, protection, enhancement and management of networks of biodiversity and green infrastructure. The benefits of green infrastructure as part of a mixed use SUE is reflected through the provision of a not inconsiderable amount of public open space lying in close proximity to additional health facilities in the form of a doctors’ surgery. These represent important benefits for the health and wellbeing of occupiers of the residential properties on the site, as well as those living on the fringes of Market Reading Field. The same features ameliorate flood risk, at the same time improve air and water quality. Public accessibility to these facilities should be seen as a benefit in terms of creating and enhancing biodiversity networks and green infrastructure.

2.55 Market Reading Field is not situated in an area at high risk of flood, and to the extent that the proposed public open space forming part of the mixed use SUE is well-connected to the countryside beyond, means that the prospects of improved connectivity between habitats is enhanced.

6. SA Objective 6: Natural Resources 2.56 The proposed development would not result in the loss of Grade 1 or 2 agricultural land, and thereby adversely affect the best and most versatile components of agricultural land. No minerals would be sterilised as a consequence of a mixed use development on Market Reading Field.

7. SA Objective 7: Pollution 2.57 The planning history of Market Reading Field does not reveal any contamination as a consequence of a previous land use, whilst paragraph 110 of the NPPF reiterates

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that in preparing plans to meet development needs, the aim should be to minimise pollution and other adverse effects on the local and natural environment. In this way, plans should allocate land with the least environmental or amenity value.

2.58 Sustainable development incorporates the regulation and monitoring of water development, with housing schemes close to existing AQMAs being likely to exacerbate air quality issues, especially in those instances where households own more than one vehicle. Accessibility to shops, services and community facilities through a network of pedestrian routes, with improved journey times to bus stops, incorporating where possible new bus routes, are measures which collectively improve air quality. These considerations should be assessed alongside the Transport Sustainability and Access Feasibility Study prepared by PFA Consulting Plc on behalf of the owners of Market Reading Field.

2.59 Water quality mitigation measures incorporating sustainable urban drainage systems and design considerations relating to issues of traffic management are important factors which have influenced the design process behind the Masterplan prepared by dparchitects.

8. SA Objective 8: Waste 2.60 The Waste Management Plan for England outlines the Government’s ambition to work towards a more sustainable and efficient approach to resource use and management. It is envisaged that sufficient opportunities will be incorporated into any proposed SUE scheme for Market Reading Field which will identify needs for the management of waste streams within individual residential units and the employment development, at the same time providing a collection point with attention focused on recycling materials.

9. SA Objective 9: Transport 2.61 The promotion of sustainable transport initiatives, including maximising the use of walking and cycling, are considerations which are tackled in the separate Transport Sustainability and Access Feasibility Study prepared by PFA Consulting Plc. The intention is to encourage a behavioural trend in the use of sustainable transport whilst mitigating potential impacts on the local and national road network. The PFA Consulting Plc report assesses the sustainability of the mixed use SUE, seen

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from the aspect of access to everyday services and facilities which future residents and employees may need. To improve access to public transport modes, and in particular to the main line railway and underground, a bus service on a circular route would be introduced as part of a proposed mixed use SUE development on the site known as Market Reading Field. Estimated trip generation rates associated with the intended mixed use SUE are set out in the Transport Sustainability and Access Feasibility Study prepared by PFA Consulting Plc.

10. SA Objective 10: Housing 2.62 Considerations surrounding future residential development in the emerging Chiltern and South Bucks Local Plan area is a topic discussed in further detail in the following chapter of these representations. It is suffice to say at this stage that a mixed use SUE commensurate with the details shown on the Masterplan Drawing No. 16 MRF SP1 prepared by dparchitects would achieve benefits in terms of open market and affordable housing in a sustainable location, at a time when the Local Plan Area is unlikely to meet its full objectively assessed housing needs. In housing sustainability appraisal terms, what is required is careful consideration paid to density and design in the light of climate change. A moderate benefit would therefore arise from the proposals advanced on behalf of the Trustees of Market Reading Field, seen from a future residential perspective.

11. SA Objective 11: Health 2.63 There are clear advantages in the creation of a large area of open space or common, allowing access to members of the public, in that it promotes healthy communities, reduces social isolation, results in improved safety and promotes social cohesion. What will be created is the provision of additional open space in an area where there is no public greenspace within 600 metres of the site, and where the nearest doctors’ surgery is situated over a kilometre away. In this way, the public open space provision forms an integral part of this small mixed use SUE, providing a link with the open countryside, being of a sufficient size to attract those living in the north eastern fringes of Amersham, primarily through walking but also through other sustainable modes of transport. A new doctors’ surgery accommodating five practitioners represents a modest benefit seen in terms of social provision to the local population present in this part of Amersham.

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12. SA Objective 12: Economy 2.64 An integral part of the mixed use SUE is the provision of a small facility to meet the requirements of seedbed enterprises, in the form of a Class B1(a)/(b) business centre amounting to 625 sq.m. (6,727 sq.ft) gross floor area of Class B1(a)/(b) business units, deliberately designed to face onto an area of public open space and thereby act as a focal point within the development. The intention in respect of this element of the proposed mixed use SUE is to allow future tenants the opportunity to expand on the same site. In these terms the proposals would lead to modest benefits seen from the viewpoint of employment. As the following chapter of these representations will reveal, there is a need for additional small commercial units to satisfy the local employment market.

G. Conclusions on the Pre- and Post-Mitigation Assessment Matrix 2.65 Table 3 overleaf comprises a pre- and post- mitigation assessment matrix where it relates to the site known as “Amersham 1 Area of Search”, excluding the land known as Quill Hall Farm, devised in accordance with the guidance set out in the Sustainability Appraisal prepared by Lepus Consulting Ltd. The pre-mitigation assessment in respect of the land known as Market Reading Field is based on a housing led scheme.

2.66 The post-mitigation assessment in respect of the same site is analysed from the viewpoint of a mixed use SUE providing much needed residential development including affordable housing, a new doctors surgery, associated public open space and a small Class B1(a)/(b) scheme to meet the future employment needs of this part of the Local Plan area, where at present negative scores are experienced against SA Objectives 10 and 12. The proposal mixed use SUE on land at Market Reading Field will provide access to a designated area of public open space, and from there to the open countryside beyond, where at present there is no lawful access permitting occupiers of surrounding residential properties to use the same land for recreational purposes (SA Objective 11).

2.67 The inevitable conclusion to emerge from this exercise is that four moderate positive sustainability objectives are likely to arise as a result of the release of Market Reading Field for a mixed use SUE, based on the Masterplan Drawing No 16 MRF SP1 prepared by dparchitects. Five further minor positive sustainability

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objectives are likely to result from the same proposals; leaving the three remaining sustainability objectives as being of negligible or no effect.

2.68 Collectively, Table 3 supports the view that the land owned by my clients should be recommended for further consideration as part of a mixed use SUE to Amersham in the emerging Chiltern and South Bucks Local Plan.

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3.00 CONSIDEATIONS RELATING TO FUTURE OBJECTIVELY ASSESSED NEEDS

I. Housing 3.01 I have referred in paragraph 1.09 to these representations to Policy CS2 of the adopted Chiltern Core Strategy in which a total of between 2,650 and 2,900 dwellings are expected to be constructed within Chiltern District Council’s administrative area over the 20 year period extending from 1st April 2006 up until 31st March 2026. This housing requirement emanates from the South East Plan which as all parties will appreciate has been partially revoked following The Regional Strategy for the South East (Partial Revocation) Order 2013 coming into force on 25th March 2013.

3.02 The Report of the Panel into the South East Plan August 2007 provided clarity on how the final housing figures set out in the partially revoked Regional Strategy were derived. Seven individual areas of consideration formed part of the process, largely emanating from what was then PPS3 “Housing”, being as follows:-

(i) Latest housing projections being CLG’s 2003 and 2004 based household projections which informed the Regional Strategy’s examination.

(ii) Current and future housing need and demand, with attention focused on the affordable housing element. Interestingly the Regional Assembly at that time saw demand as almost limitless within this region.

(iii) Current and future affordability levels.

(iv) Economic growth forecasts;

(v) Housing land availability focusing attention on urban renewal and previously developed land.

(vi) Infrastructure.

(vii) Sustainability Appraisal.

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3.03 It follows that the South East Plan’s approach was not based on identifying and then meeting the full objectively assessed housing needs in a Local Planning Authority’s administrative area in the way now envisaged in the NPPF. The NPPF requires development plans/local plans to meet objectively assessed needs, unless “any adverse impacts of doing so would significantly and demonstrably outweigh the benefits”; whilst the South East Plan’s approach sought to achieve a “balance” based on those factors set out in the previous paragraph, as opposed to demonstrating that the adverse impacts significantly and demonstrably outweigh the benefits.

3.04 The materially different approach towards future housing provision adopted by the NPPF, compared to that required under the Regional Strategies, isa matter which has been highlighted in the High Court judgement Gallagher Homes Ltd Lioncourt Ltd v Solihull Metropolitan Borough Council (2014) EWHC 1283(Admin), where Hickinbottom J identified the “substantive error” in the Inspector’s decision as “a failure to grapple with the issue of full objectively assessed housing need, with which the NPPF required him, in some way, to deal.” (my emphasis) Housing data from an earlier Regional Strategy exercise can be used in preparing a Local Plan, but as the Judge said in paragraph 98:-

“… Where, as in this case, the plan-maker uses a policy or figure from an earlier Regional Strategy, even as a starting point, he can only do so with extreme caution – because of the radical policy change in respect of housing provision effected by the NPPF.” (my emphasis)

3.05 Hickinbottom J found that the NPPF departed from PPS3 in two important ways: (a) the abandoning of the “regional, top down” approach in favour of localism, with a duty to co-operate with neighbouring authorities, and (b) by placing considerable emphasis on the policy imperative of increasing the supply of housing. Under paragraph 47 of the NPPF, the Judge said that the housing needs are “not just a material consideration, but a consideration of particular standing.” In addition paragraph 97 of the judgement addressed the “major policy changes in relation to housing supply brought into play by the NPPF”, noting that:-

“Unlike its predecessor, (which required a balancing exercise involving all material considerations, including need, demand and relevant policy factors) the NPPF requires plan-makers to focus on full objectively assessed needs for housing, and to meet that need

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unless (and only to the extent that) other policy factors within the NPPF dictate otherwise. That, too, requires a balancing exercise; - to see whether other policy factors significantly and demonstrably outweigh the benefits of such housing provision – but that is a very different exercise than that required pre-NPPF.” (my emphasis)

3.06 As a consequence the Judge held at paragraph 94 of the transcript that paragraph 47 of the NPPF requires full housing needs to be objectively assessed in some way, and that it was insufficient for NPPF purposes for all material considerations (including need, demand, and other relevant policies) simply to be weighed together. He said at paragraph 94:-

“Paragraph 47 requires full housing needs to be objectively assessed, and then a distinct assessment made as to whether (and, if so, to what extent) other policies dictate to justify constraint. Here, numbers matter; because the larger the need, the more pressure will or might be applied to infringe on other inconsistent policies. The balancing exercise required by paragraph 47 cannot be performed without being informed by the actual full housing need.”

3.07 The decision of the High Court was challenged in the Court of Appeal by the Local Planning Authority in Solihull Metropolitan BC v Gallagher Estates Ltd and Lioncourt Homes (2014) EWCA Civ 1610 at which time Leading Counsel on behalf of the Authority submitted that:-

i) The Judge was wrong to conclude that in respect of housing provision the NPPF effected a “radical change” (a phrase used by the Judge below at paragraph 98 of his judgement) from the previous policy articulated in PPS3.

ii) The Judge was also wrong to hold that NPPF paragraph 47 required a two- step approach: first, an objective assessment of full housing needs, and secondly an assessment as to whether other policies dictate or justify constraint.

iii) The Judge should have held that the process by which the Inspector came to recommend adoption of the SLP (Solihull Local Plan) satisfied the requirements of NPPF paragraph 47.

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iv) The Judge should have held that the Inspector was entitled to conclude (as a matter of planning judgement) that the objective assessment of needs (OAN) was “embedded” in the earlier work and what is called the Phase II RSS Review Panel.

3.08 It is suffice to say that on all four points, the challenge raised by Solihull MBC failed before the Lord Justices in the Court of Appeal, who in turn upheld the decision of the High Court.

3.09 In short, an objectively assessed housing needs exercise does not require an examination of policy constraints such as the extent of the Metropolitan Green Belt and/or Chilterns AONB. The objectively assessed housing need is considered to be a “policy-off” figure, prior to a consideration being given to meeting the full objectively assessed needs having regard to any environmental constraints.

3.10 The Buckinghamshire HEDNA report of January 2016 reveals a radical change in the number of market and affordable dwellings comprising the overall objectively assessed housing need for both Chiltern District and South Bucks District administrative areas over the period 2013 to 2033. A total of 13,653 dwellings are recorded as being needed over this 20 year time period, of which 6,602 would be attributable to the area of Chiltern District Council, and 7,051 to South Bucks District Council. The emerging Chiltern and South Bucks Local Plan covers a period from 2014 to 2036, with the objectively assessed housing need comprising a total of 15,100 dwellings, of which 7,300 are attributable to Chiltern District Council’s administrative area, with the remaining 7,800 anticipated as being met by South Bucks District Council.

3.11 Whatever objectively assessed housing need figure is taken, there are almost 1,800 households needing affordable housing at the start of the Plan period; with the consequence that if it is considered appropriate to maximise affordable housing provision in the early years of the emerging Local Plan; this in itself may result in the overall levels of housing delivery in the Plan area being compromised.

3.12 The Buckinghamshire HEDNA Report has considered market signals within the Buckinghamshire Housing Market Area, taking into account house prices, rents,

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affordability, overcrowding and the rate of development. With affordability alone being approximately double the level associated with “modest” pressure, an overall uplift of 20% of the housing needs figure, identified from the most recent household projections published by DCLG, is proposed.

3.13 It is fairly acknowledged by both Authorities responsible for preparing the Chiltern and South Bucks Local Plan that in housing terms alone, the objectively assessed housing needs figures referred to above represent a significant challenge, given the collective responsibilities of both Authorities to try and meet the requirements set out in the Buckinghamshire HEDNA Report within the Local Plan area.

3.14 It is noted from a letter dated 4th December 2015 written to Aylesbury Vale District Council concerning that Authority’s Issues and Options Consultation Document, that the Head of Sustainable Development at Chiltern District Council has indicated that only 7,600 of the 15,100 dwellings derived from the objectively assessed needs study are considered potentially deliverable over the period of the emerging Chiltern and South Bucks Local Plan. A majority of the sites coming forward to meet this delivery requirement are expected to be on land situated in the Metropolitan Green Belt and Chilterns AONB, where mitigation measures are required, and where the selected sites are expected to accord with the principle of sustainable development, as well as securing the necessary infrastructure.

3.15 In the event that this initial opinion is followed, it means that approximately 50% of the objectively assessed housing needs of the emerging Chiltern and South Bucks Local Plan area will be expected to be met by adjoining authorities, of which Aylesbury Vale appears to be the prime candidate. At the current time, no indication is given of the extent to which any objectively assessed housing needs exercise, particularly concerning that land in South Bucks District Council’s administrative area, can be successfully accommodated by those Authorities in East Berkshire, comprising part of what is a separate Housing Market Area.

3.16 The gravity associated with the current housing position confronting Chiltern and South Bucks District Councils’ administrative areas cannot be fully assessed at the present time. This is because the exercise by the respective authorities in

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accommodating the objectively assessed housing need arising from the emerging Chiltern and South Bucks Local Plan, resulting in a “policy on” housing requirement figure, has for understandable reasons, still to be undertaken. Equally, it would be wrong to assume that sites recommended for possible release from the Green Belt and Chilterns AONB, whether reliant on the report from Ove Arup & Partners or otherwise, are available or deliverable within the time frame of the emerging Local Plan, which of itself dictates that there should be a wide range of potential sites considered as part of the next stage of the Local Plan exercise.

3.17 The acuteness of the housing land supply position both now and into the future confronting the Chiltern & South Bucks Local Plan area is a matter illustrated in Table 4 overleaf, which reproduces Appendix 5 taken from the Draft Housing and Economic Land Availability Assessment produced by the respective Authorities, but concentrates attention solely on the main settlement of Amersham, and on those sites deemed suitable, available and achievable for residential and employment uses over the next 15+ years. In the same way as your own HELAA study, Table 4 does not consider i) sites of less than 5 dwellings (net) or under 0.25 ha of economic development floorspace; ii) sites which do not constitute previously developed land, either within or adjoining Amersham; iii) on-going employment sites not recommended for release; iv) sites within the Metropolitan Green Belt not comprising previously developed and v) sites with environmental constraints.

3.18 A number of conclusions can be drawn from Table 4:-

A. A maximum of 313 dwellings are expected to be constructed over a 15+ year period, 34% of which are not intended to be built until the last delivery period of the Local Plan. The 313 dwellings are expected to be accommodated on 11 individual sites to be developed for either mixed use or residential purposes, with a maximum of 80 dwellings constructed in the first five year period, equivalent to 18 dwellings per annum, in one of the four main settlements in Chiltern District Council’s administrative area.

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B. Residential development is to take place on 6 sites during the first 5 year period. Four sites have been granted planning permission or else benefit from “permitted development rights” under the prior approval procedure. Of the remaining two sites, The Pheasant Public House, 35 Plantation Road, Amersham has revealed a lower capacity at five dwellings following the resolution to grant planning permission. The remaining site known as Robindene, Grimsdells Lane, Amersham was the subject of an appeal dismissed on 21st January 2014 on the basis that there were inadequate reasons to justify its release as an employment generating site.

C. Two sites are expected to deliver residential development in the 6-10 year period, both of which are to form part of mixed use redevelopment schemes. The development of the Springfield Industrial Estate is subject to all the landowners signing up to the principle of redeveloping the same land, which is still to be confirmed, and there is a need to clarify the position regarding restrictive covenants which your Council accepts “could limit the development potential of the site”. Doubts must therefore be registered as to the achievability and deliverability of this site.

D. Only three sites are considered to be suitable and potentially deliverable in the period beyond 10 years in the HELAA study. One of the three sites is a publicly owned car park which your Council accepts will have to be retained, being in the ownership of Chiltern DC. Even in this case, extensive consultation and stakeholder discussions are expected to take place which it is said would involve a potentially lengthy planning process.

The other two sites comprise the Chiltern Pools and Gym, Amersham Library and Youth Centre, and the Council’s offices and adjoining uses situated in King George V Road, Amersham, all of which are important local community facilities. Both sites are expected to retain their respective community uses, as well as being capable in principle of redevelopment for civic, commercial and/or residential uses. It is contended that the level of housing provision is both highly optimistic and fraught with uncertainty, resulting in serious doubts being raised over whether any of these three sites will be deliverable in the longer term.

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3.19 The potential release of Market Reading Field as a mixed use SUE is required to be seen in the context of the conclusions drawn from Table 4, which illustrates a serious problem in finding suitable sites within the built up area of Amersham to meet the future residential requirements of the emerging Chiltern and South Bucks Local Plan. The site owned by the Trustees of Market Reading Field is suitable, achievable and deliverable within the next five years, with no displacement of any existing employment, parking, community, or other cultural forms of development, with the result that its release would lead to distinct benefits, furthering the future needs of Amersham and the Local Plan area generally.

II. Employment Generating Development 3.20 Table 4 reveals that there is only one site in the built up area of Amersham that is likely to come forward for employment generating purposes over the next 15+ years, and even this site at 42/44 London Road West, Amersham would only be suitable if the exception and sequential flooding tests can be met. There are no sites within the built up area of Amersham likely to come forward for employment generating purposes in the first ten years of the emerging Local Plan period.

3.21 This factor has to be seen at a time when landowners are taking advantage of the provisions of Schedule 2, Part 3 Class O of the Town & Country Planning (General Permitted Development (England) Order 2015, converting Class B1(a) office floorspace into Class C3 dwellinghouses. The Buckinghamshire HEDNA Assessment along with the stakeholder workshop meeting held on 19th May 2015 both confirm that “permitted development rights” have contributed to the perceived decline in town centre office accommodation, resulting in difficulties in predicting future office supply.

3.22 It has been noted that the Chiltern Employment Land Needs Assessment 2013 found that Chiltern District has a relatively localised and self-contained property market, with a mixed industrial and office character, largely reflected the District’s key employment sectors of professional services, digital and creative media, and healthcare. Amersham has historically provided an important main centre for employment floorspace, with the attraction being relatively low rents particularly when compared with adjoining centres and Central London, albeit in a location where there is a skilled local workforce and high quality of life. Many local firms

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are long established but infrastructure and accessibility constraints have limited the size of firm that can realistically locate within Chiltern District Council’s administrative area.

3.23 The stakeholder workshop meeting held on 19th May 2015 found that micro businesses struggle to find suitable premises for expansion/growth, which has inhibiting constraining effects, although most of the demand for employment floorspace comes from existing local businesses wanting to expand, rather than businesses wanting to move in from outside the area. Broadband connectively was held to be important for businesses, although the level of connectivity varies across the area. It was found that older premises were not meeting the needs of local businesses which require flexible modern style accommodation. Seedbed units were held at the same stakeholder workshop meeting as having “proven very successful”, with more of these types of site needed.

3.24 Future employment growth is anticipated to come primarily from the Class B1(a)/(b) sectors, with an additional 15ha of land being proposed for economic development over the duration of the Chiltern and South Bucks Local Plan period, of which 2ha were to be attributable to the area covered by Chiltern District Council. This is despite the fact that based on forecasts prepared by Experian, there was an indicative need for 9ha of land for additional Class B1(a)/(b) over the period 2014 to 2036.

3.25 The Buckinghamshire HEDNA report, in considering the demand/supply of employment floorspace stated: “There is considered to be a lack of flexible space that is suitable for start-ups or for SMEs looking to expand.” The same study recommended that there was likely to be an issue arising from the non-delivery of local plan allocations and sites with planning permission, in that there may be uncertainty as to whether the same land would be delivered. The conclusion on the same topic went on to state that “If this is the case, then the local authority would have a shortfall of employment floorspace. As such, each local authority may choose to build in a buffer in its land allocation to account for non-delivery of sites.

3.26 The 627 sq.m (6727 sq.ft) of Class B1(a)/(b) business units forming part of the mixed use SUE on Market Reading Field is well placed to address the problems

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highlighted in the Buckinghamshire HEDNA report and stakeholder workshop meeting held on 19th May 2015 concerning the demand/supply of Class B1(a)/(b) floorspace in the Amersham area. An integral part of the current proposals will provide important flexible seedbed floorspace in an attractive setting, thereby contributing to the future employment generating needs of the Chiltern and South Bucks Local Plan area.

III. Doctors Surgery 3.27 The Chiltern and South Bucks Settlement Infrastructure Capacity Study has shown that in Amersham there is insufficient information currently available on constraints relating to primary healthcare. The same study highlighted the fact that in considering current infrastructure capacity and the potential to accommodate growth within a timeline, there was widespread pressure across Chiltern District on GP capacity, according to the Chiltern Commissioning Group. In responding to capacity improvements to primary health care, it was said as part of the same study that there was “very limited scope due to the pooling of Section 106 contributions. This type of infrastructure could be covered by CIL.”

3.28 The provision of a doctors’ surgery as a focal point within the mixed use SUE is not a facility required to meet the needs of the residential component of the same composite use, in that less than 1500 people would be accommodated on Market Reading Field. It is this level of residential growth that would trigger the need for additional GP’s. However, it is a known fact that the nearest GP is more than a kilometre away, which is in excess of the maximum sustainable distance to a facility such as a doctors’ surgery, having regard to the study entitled “Shaping Neighbourhoods: 2010” prepared by Barton et Al.

3.29 The provision of a doctors’ surgery as part of the mixed SUE on land owned by the Trustees of Market Reading Field, catering for 5 practitioners, would meet the combined needs of those future households occupying the same site, together with the requirements of adjoining residential development. Seen in these terms the same health care facility can only comprise a positive measure at a time of restrictions on public health expenditure, with anticipated needs in the future remaining uncertain.

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IV. Public Open Space 3.30 A designated area of public open space, taking on the role of a common, comprising part of the mixed use SUE performs a number of functions, all of which result in a wider benefit to the north eastern part of Amersham. It allows residents of the proposed development and those living in the surrounding area to use accessible natural green space, without having to negotiate barriers in the form of roads or railways which may otherwise disincentivise local residents from enjoying the same facility.

3.31 The presence of a doctors’ surgery, along with a small Class B1(a) and (b) employment generating development provide additional focal points encouraging the use of a proposed area of natural green space, thereby assisting in the promotion of healthy living, at the same time resulting in increased social cohesion. The location of the accessible natural green space presents an opportunity for improvements to be made to biodiversity seen in a wider context, given the location of the same public open space lying close to an area of open countryside. It also performs a supplementary role in allowing a wider appreciation of the Chilterns AONB, its associated droving routes, prehistoric scarp earthworks of hillforts and burial mounds, and above all enjoyment of its characteristic chalk river valleys.

3.32 The creation of an area of public open space as part of a mixed use SUE found within a contained parcel of land surrounded by substantial tree screening would not adversely impinge on the topography of the surrounding landscape or adversely affect views into or out of the wider open countryside. To this end, the area of public open space should be seen as an integral part of a mixed use development, reflecting the concept of Metroland, with buildings laid out in a spacious manner representative of the local architectural vernacular, supplemented by additional tree and hedge planting.

3.33 In this way, the public open space forms part of a closed loop ecosystem approach, allowing consideration to be given to the opportunities for evapotranspiration and run-off catchment through tree and woodland planting and urban greening. It offers the opportunity to create valuable sustainable urban drainage as part of a

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process in managing run-off and water quality, at the same time assisting in groundwater recharge in an area possessing chalk streams and aquifers.

V. Chilterns Area of Outstanding Natural Beauty 3.34 It is accepted that in accordance with the provisions of paragraph 115 of the NPPF, great weight should be given to conserving landscape and scenic beauty in an Area of Outstanding Natural Beauty, which enjoys the highest status of protection. The Chilterns Area of Outstanding Natural Beauty Management Plan 2014-2019 “A Framework for Action” sets out the origins, opportunities for change and special qualities of the same designated landscape:-

1. In 1965 an area of 800 sq.kms of the Chilterns was designated as an Area of Outstanding Natural Beauty (AONB). Later, following a review of the boundary, the AONB was enlarged to 833 sq.kms in 1990. Natural England has recently lifted its de facto moratorium of the review of boundaries of AONBs and there may well be an opportunity during the lifetime of this Plan to consider proposals to change the existing boundary.

2. The Chilterns AONB was designated for the natural beauty f its landscape and its natural and cultural heritage. In particular it was designated to protect its special qualities which included the steep chalk escarpment, with areas of flower-rich downland, woodlands, commons, tranquil valleys, the network of ancient routes, villages with their brick and flint houses, chalk streams and rich historic environment of hillforts and chalk figures.

3.35 It is relevant to state that the use of Market Reading Field as a mixed use SUE would not adversely affect those features representative of the natural beauty of the Chilterns AONB landscape, neither would it impact upon its natural and cultural heritage, a conclusion which is in contrast to the land forming part of Quill Hall Farm, when assessing the impact of the proposed development on the same designated landscape.

3.36 On the contrary, a combination surrounding the siting of the public open space forming part of the proposed mixed use SUE, and the open countryside beyond supports one of the important themes having a significant influence on the management of the Chilterns AONB. In this regard, the document entitled “A Framework for Action” states the following in respect of the cross cutting theme of “health and well-being”:-

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“Rising obesity levels and the ever increasing costs of healthcare have prompted a much greater emphasis on preventative health solutions. There is an increasing perception of the countryside, and green space in general, as a place which offers tangible benefits to health and well-being. The value of protected countryside, like AONBs, in providing walking, cycling and riding routes, and a tranquil rural escape from stressful lives is increasingly being seen in economic and social terms as well as environmental. “

3.37 It is a matter acknowledged by all practitioners that the Chilterns AONB and surrounding areas are facing pressure to accommodate significant number of new houses, along with other much needed development; and this requires particular regard being paid to the scale of developments and their impact on the setting of the same designated landscape. The retention of open space and the need to restrict the scale of new development are key components in conserving the natural beauty of an AONB, with new green infrastructure providing an important role in alleviating some of the pressures from existing development in a pleasant environment.

3.38 The owners of Market Reading Field recognise that there is a requirement to respect vernacular architecture, settlement character and the local landscape, encouraging a true sense of place, at the same time actively promoting environmentally sensitive construction methods and necessary skills, particularly in the use of locally produced building materials. This involves the highest environmental standards to minimise impact on the environment and help mitigate the causes of climate change.

3.39 Market Reading Field is of a size, particularly when seen in terms of its developable area, which will meet those principal characteristics commensurate with the landscape and scenic beauty, for which the Chilterns AONB is renowned, at a scale which would avoid having a harmful impact on its setting. What is proposed allows for the distinctive vernacular architecture of the Chilterns to be replicated in a mixed use development, at the same time allowing for generous landscaping works to create a sense of place. Above all, it means the proposed development can be spaciously arranged, reflecting the sense of place conditioned by earlier advertisements depicting the juxtaposition of the settlement of Amersham with open countryside.

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3.40 What is apparent is that any extension to Amersham, aside from encroaching onto the Metropolitan Green Belt, will also involve utilising land in the Chilterns AONB. No distinction is drawn in prioritising smaller sites in preference to larger sites, since that does not lessen the policy objective which should be given to conserving landscape and scenic beauty in AONBs.

3.41 Paragraph 116 of the NPPF states that planning permission should be refused for major developments in these designated areas except in exceptional circumstances, and where it can be demonstrated they are in the public interest; before setting out three points which should be assessed as part of the consideration of any proposal. These three points are examined in detail below. Meanwhile, it should be emphasised that there is no policy advice which differentiates potential sites on the basis of their size or character when considering whether it constitutes a “major development” in an AONB. In this regard the contents of paragraph 005 Reference ID:8-005-201403016 of the NPPG are clear:-

“…whether a proposed development in these designated areas should be treated as a major development, to which the policy in paragraph 116 of the Framework applies, will be a matter for the relevant decision-taker, taking into account the proposal in question and the local context. The Framework is clear that great weight should be given to conserving landscape and scenic beauty in these designated areas, irrespective of whether the policy in paragraph 116 is applicable.”

3.42 These representations have already set out the nature of the proposed development advanced on behalf of the Trustees of Market Reading Field, constituting a mixed use SUE to Amersham. A scheme of the type set out in the Masterplan Drawing No. 16 MRF SP1 prepared by dparchitects, seen in a local context, has also been addressed in these representations. If it is contended that the current proposals comprise a “major development” in the Chilterns AONB, then it is relevant to consider the three points which may lead to material considerations weighing in favour of the release of Market Reading Field for a mixed use SUE.

A. The Need for the Development 3.43 It has been demonstrated earlier that compared with earlier housing policy figures based on the South East Plan, there has been a radical change in the number of market and affordable dwellings required to meet the overall objectively assessed

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housing need in the Chiltern and South Bucks Local Plan area over the period 2013 to 2033. This will, as accepted by your Authority and South Bucks DC, be a challenging task, necessitating a review of existing Green Belt boundaries based on the “exceptional circumstances” test set out in paragraph 83 of the NPPF. The need is pressing, to the extent that even at this early stage, assurances are being sought from adjoining Authorities of the ability to take as much as 50% of the emerging Local Plan’s objectively assessed housing needs, despite likely releases of land being required from the Metropolitan Green Belt.

3.44 It follows on any analysis, and given the objective of national policy set out in the Framework of “boosting significantly the supply of housing” as part of the Governments’ focus on improving the economy, that where the Metropolitan Green Belt boundary is contiguous with that of the Chilterns AONB boundary; the need for a development of the kind now proposed on Market Reading Field is of paramount importance, seen from the aspect of existing AONB policy.

3.45 The contribution made by the land owned by the Trustees of Market Reading Field is twofold. From a housing perspective, it will lead to the release of land to meet much needed local housing provision, where otherwise as indicated through the contents of Table 4, uncertainty exists over the availability, achievability and deliverability of sites to meet future needs. Equally significant is the provision of much needed small flexible Class B1(a)/(b) accommodation to cater for small seedbed enterprises in the local area, which is scarce, and for which there is a readily available workforce. The provision of a doctors’ surgery and additional public open space are distinct benefits not only in respect of the mixed use SUE itself, but to surrounding residential development. These factors are evident from Table 3 which compares the pre-mitigation position concerning a housing led proposal, from the post-mitigation position based solely on the release of Market Reading Field from the “Amersham 1 Area of Search”.

3.46 Secondly, the release of Market Reading Field as a mixed use SUE would take place on land occupying a sustainable location, having least adverse impact on the purposes of the Metropolitan Green Belt, as well as the primary objective behind the Chilterns AONB; a matter demonstrated in these representations.

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B. The Cost of, and Scope for, Developing Elsewhere 3.47 It is often the case that third parties opposing developments do so on the basis that it should be accommodated on previously developed, rather than greenfield sites. The likelihood of this situation being achieved insofar as future housing and employment generating development in the Chiltern and South Bucks Local Plan area is concerned, whilst preferable, is unrealistic; unless a conscious attempt is made, in contravention of national policy, not to respond to the Local Plan area’s objectively assessed needs. That scenario has uncertain and potentially devastating consequences.

3.48 Even if certain urban sites become available, it is likely given the extent of future housing and employment requirements, that the Local Plan area will face a significant housing and employment shortfall in the short term, with no real prospects of improvements to public open space and healthcare facilities in and around Amersham. It is therefore important, even in Authorities which are highly constrained by environmental factors, to release those sites which are the most sustainable and appropriate in terms of scale, to cater for the future needs of the Local Plan area. Above all, there is no evidence which shows that the Local Plan’s future objectively assessed needs can be addressed solely through the use of previously developed land, save to an extremely limited extent.

C. Any Detrimental Effect on the Environment or Landscape and the Scope for Mitigation.

3.49 The primary concern relating to the impact of the mixed use SUE on the Chilterns AONB is a loss of an open area of scrubland for housing, employment, healthcare and public open space provision. The land which forms the subject of these representations is not in agricultural use or for that matter used for any other countryside recreational purpose, with its appearance of worn tracks revealing unlawful entry by members of the public.

3.50 What is now proposed in these representations would not lead to the loss of any fields which make a positive contribution to the setting of this part of the Chilterns AONB. On the contrary, Market Reading Field represents an open parcel of flat land of no particular landscape quality synonymous with this part of the Chilterns AONB, save for being free of built development. It would not involve the loss of

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any high quality or versatile agricultural land, or trees or hedgerows of any amenity value, neither would it affect the setting of any listed building or other heritage assets.

3.51 In the writer’s judgement, a spaciously arranged SUE, complete with the provision of a not inconsiderable amount of transitional public open space provision, close to a position where it adjoins the surrounding open countryside, would result in visual improvements beyond the existing situation, being seen as an enclosed parcel of land with substantial mature coniferous and deciduous tree planting. Considerable advantages will therefore arise through mitigation, especially as any new built development would not appear dominant in localised views from within, or indeed outside of the site owned by The Trustees of Market Reading Field.

3.52 To these considerations should be added that there is no evidence to show that areas of poorer quality land in terms of their agricultural classification are available and should be used in preference to that comprising Market Reading Field.

3.53 It follows that at a time where there is a site which is suitable, available and deliverable within the first five year period of the emerging Chiltern and South Bucks Local Plan, capable of performing the role of a mixed use SUE bordering one of the main settlements in your administrative area; serious consideration should be given to its potential release to meet a number of current needs. This is particularly the case where the land in question can be shown to satisfactorily mitigate any adverse implications arising from its location within the Metropolitan Green Belt and Chilterns AONB.

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4.00 CONCLUSIONS 4.01 These representations, including the Site Location and Masterplan drawings prepared by dparchitects, should be considered alongside a separate Transport Sustainability and Access Feasibility Study prepared by PFA Consulting Plc, directed at a triangular shaped parcel of land amounting to 8.97 ha (22.15 acres) known as Market Reading Field. The same parcel of land comprises a developable area of 6.76ha (16.69 acres), served by an existing access of Eagle Close, with a separate pedestrian access off Quill Hall Lane, Amersham, Buckinghamshire HP6 6LL.

4.02 The site is owned by the Trustees of Market Reading Field, and it is their intention to create a sustainable urban extension to the north eastern side of Amersham, catering for around 50 dwellings; a large area of public open space; 625sq.m (6727 sq.ft) of Class B1(a)/(b) business units, along with a doctors’ surgery accommodating five practitioners. It is my clients’ view that Market Reading Field is well placed to meet the provisions of Option C set out in Regulation 18 Issues and Options Consultation document.

4.03 These representations along with those prepared by PFA Consulting Ltd are directed solely to Market Reading Field, where it is shown as forming part of a larger green belt strategic option in the Issues and Options Public Consultations document. They do not envisage, nor do they seek to justify the release of land known as Quill Hall Farm forming part of the same green belt strategic option.

4.04 Paragraphs 83 and 84 of the NPPF are complementary provisions in that in reviewing Green Belt boundaries, attention is required to be focused on “sustainable patterns of development”. During any review process “the consequences for sustainable development” must be carefully considered, a matter re-affirmed through the first bullet point of paragraph 85 of the NPPF. Current national policy, whilst appearing to reinforce the need to protect Green Belts, is equally capable of being interpreted more broadly. In this way, “the consequences for sustainable development” may require revision to a Green Belt boundary, an important factor in the light of the first sentence of paragraph 4.7 of the Chiltern and South Bucks Local Plan Initial Consultation (Regulation 18) Issues and Options Document, viz: “Given the overall levels of need and limited scope for development to meet that need, the council

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consider there are exceptional circumstances to review the Green Belt.” (my emphasis)

4.05 It follows that your Council along with South Bucks District Council, have identified “exceptional circumstances”, justifying a review of the Metropolitan Green Belt boundaries within the respective local planning authority areas. This conclusion is based on meeting future development needs, and in particular that relating to the full objectively assessed housing needs of both Councils, as taken from the Buckinghamshire HEDNA Report and the Chiltern District Council and South Bucks District Council Draft HELAA report of January 2016. The comprehensive nature of the Draft HELAA report inevitably means that opportunities to satisfy future housing requirements in the Local Plan area from sites within main or secondary settlements is severely limited, irrespective of any loss of land or facilities devoted to employment or leisure purposes.

4.06 The material changes in circumstances relating to future housing provision arise as a consequence of the requirements of paragraph 47 of the NPPF. The issue facing your Authority and South Bucks District Council is “whether, in the exercise of planning judgement and in the overall context of the positive statutory duty to achieve sustainable development, exceptional circumstances exist to justify the release of Green Belt?” In my client’s view, the answer where it relates to the release of Market Reading Field as a mixed use SUE to Amersham is emphatically ‘yes’.

4.07 The NPPG does not provide any specific guidance on the methodology to be adopted in undertaking a Green Belt Assessment. It is nevertheless apparent from current central government policy and other Green Belt Assessments carried out in the period following the introduction of the NPPF, that a Green Belt Assessment cannot be undertaken simply on the basis of assessing land against the five purposes of a Green Belt, whatever methodological approach is chosen to quantify/qualify the parcel of land in question.

4.08 Sustainable development considerations seen across the whole spectrum of the same topic, play an important primary role in Green Belt Assessments, influencing the suitability of land for development to meet the future needs of districts. The potential sustainability of locations for development is influenced by the site’s

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accessibility, environmental constraints, and where opportunities exist, the prospect of enhancing or supporting existing communities. It follows that sustainable development considerations are required to be examined as an integral or intrinsic part of the process associated with a Green Belt Assessment. In the case of Market Reading Field, its release as a mixed use SUE would be at a scale commensurate with the size of Amersham, and hence should be afforded particular priority in satisfying future development requirements.

4.09 These representations have shown that Ove Arup & Partners in their Buckinghamshire Green Belt Assessment Part 1A: Methodology have assessed General Area 22b predominantly from the perspective of Quill Hall Farm, and not from that of Market Reading Field, as the photographic evidence accompanying these representations clearly demonstrate.

4.10 In considering Purpose 1b, the extent to which the borders of Quill Hall Farm can be said to be “lacking in durability or permanence” is fundamentally different from the position compared with the parcel of land known as Market Reading Field. In contrast to Quill Hall Farm, Market Reading Field has a prominent, permanent and consistent boundary with the built-up area of Amersham. The same land is well contained, having durable boundaries consisting of a dense mix of deciduous and coniferous tree planting, which on its longest boundary coincides with the Metropolitan railway line to Chesham, found at grade, as well as in a small cutting.

4.11 In a similar way, Ove Arup & Partners’ assessment of General Area 22b from the viewpoint of Purpose 2 and the need to protect the openness of the countryside, is unreflective of the situation applying to Market Reading Field. There is support for this opinion in that the site photographs accompanying General Area 22b in the Ove Arup & Partners Green Belt Assessment show views across Quill Hall Farm from Stubbs Wood and from Quill Hall Lane, in complete contrast to the prominent, permanent, and consistent dense boundary tree screen enclosing Market Reading Field, for which no comparable photographs are included.

4.12 It is a matter of common ground that in terms of Purpose 3 of the Buckinghamshire Green Belt Assessment undertaken by Ove Arup & Partners, Market Reading Field scores identically to three of the four other parcels of land considered suitable

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candidates for further consideration for release from the Metropolitan Green Belt. In assessing the land owned by the Trustees of Market Reading Field against Purpose 4, it scores more favourably than any other parcel of land to be carried forward for further consideration as a suitable built area extension option to Amersham.

4.13 Table 1 of these representation demonstrates that Market Reading Field, looked at independently from Quill Hall Farm and other adjoining land, should be recommended for further consideration as a built area extension option around Amersham. This is because the results of a reappraisal of the functions of the Metropolitan Green Belt where it concerns land in my clients’ ownership, compare favourably with all other parcels of land situated on the built up edges of the same main settlement which are considered suitable candidates for release from the same Green Belt in the Buckinghamshire Green Belt Assessment Part 1A: Methodology.

4.14 The Sustainability Appraisal prepared by Lepus Consulting dated January 2016 assesses both Quill Hall Farm and Market Reading Field on the north eastern side of Amersham in the context of what is referred to as “Amersham 1 Area of Search”, comprising a possible built area extension option to the same main settlement. “Amersham 1 Area of Search” is assessed against 12 separate sustainability objectives. These representations have examined Market Reading Field independently from the rest of the “Amersham 1 Area of Search” in the context of pre-mitigation measures directed at a housing led development of the same parcel of land. A Post-Mitigation Sustainability Appraisal of Market Reading Field as a mixed use SUE is set out at Table 3 of these representations.

4.15 The inevitable conclusion to emerge from Table 3 is that four moderate positive sustainability objectives are likely to arise as a result of the release of Market Reading Field for a mixed use SUE, based on the Masterplan Drawing No 16 MRF SP1 prepared by dparchitects. Five further minor positive sustainability objectives are likely to result from the same proposals; leaving the three remaining sustainability objectives as being of negligible or no effect.

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4.16 It follows that looked at collectively, Table 3 further supports the view that the land owned by my clients should be recommended for further consideration as part of a mixed use SUE to Amersham in the emerging Chiltern and South Bucks Local Plan.

4.17 The Buckinghamshire HEDNA report of January 2016 reveals a radical change in the number of market and affordable dwellings comprising the overall objectively assessed housing need for both Chiltern District and South Bucks District administrative areas over the period 2013 to 2033. There are almost 1,800 households needing affordable housing at the start of the Plan period; with the consequence that if it is considered appropriate to maximise affordable housing provision in the early years of the emerging Local Plan; this in itself may result in the overall levels of housing delivery in the Plan area being compromised.

4.18 The Buckinghamshire HEDNA Report has considered market signals within the Buckinghamshire Housing Market Area, taking into account house prices, rents, affordability, overcrowding and the rate of development. With affordability alone being approximately double the level associated with “modest” pressure, an overall uplift of 20% of the housing needs figure, identified from the most recent household projections published by DCLG, is proposed.

4.19 It is fairly acknowledged by both Authorities responsible for preparing the Chiltern and South Bucks Local Plan that in housing terms alone, the objectively assessed housing needs figures represent a significant challenge, given the collective responsibilities of both Authorities to try and meet the requirements set out in the Buckinghamshire HEDNA Report within the Local Plan area. The gravity associated with the current housing position in the emerging Local Plan area, and the acuteness of the housing land supply position in the foreseeable future, is a matter illustrated by conclusions drawn from Table 4 of these representations.

4.20 The Chiltern Employment Land Needs Assessment 2013 found that Chiltern District has a relatively localised and self-contained property market, with a mixed industrial and office character. Amersham has historically provided an important main centre for employment floorspace, with the attraction being relatively low

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rents particularly when compared with adjoining centres and Central London, albeit in a location where there is a skilled local workforce and high quality of life.

4.21 The stakeholder workshop meeting held on 19th May 2015 found that older premises were not meeting the needs of local businesses which require flexible modern style accommodation. Seedbed units were held at the same stakeholder workshop meeting as having “proven very successful”, with more of these types of site needed.

4.22 Future employment growth is anticipated to come primarily from the Class B1(a)/(b) sectors, with an additional 15ha of land being proposed for economic development over the duration of the Chiltern and South Bucks Local Plan period, of which 2ha were to be attributable to the area covered by Chiltern District Council. This is despite the fact that based on forecasts prepared by Experian, there was an indicative need for 9ha of land for additional Class B1(a)/(b) over the period 2014 to 2036.

4.23 The 627 sq.m (6727 sq.ft) of Class B1(a)/(b) business units forming part of the mixed use SUE on Market Reading Field is well placed to address the problems highlighted in the Buckinghamshire HEDNA report and stakeholder workshop meeting held on 19th May 2015 concerning the demand/supply of Class B1(a)/(b) floorspace in the Amersham area. An integral part of the current proposals will provide important flexible seedbed floorspace in an attractive setting, thereby contributing to the future employment generating needs of the Chiltern and South Bucks Local Plan area.

4.24 The provision of a doctors’ surgery as part of the mixed SUE on land owned by the Trustees of Market Reading Field, catering for 5 practitioners, would meet the combined needs of those future households occupying the same site, together with the requirements of adjoining residential development. Seen in these terms the same health care facility can only comprise a positive measure at a time of restrictions on public health expenditure, with anticipated needs in the future remaining uncertain.

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4.25 A designated area of public open space, taking on the role of a common, comprising part of the mixed use SUE, performs a number of functions, all of which result in a wider benefit to the north eastern part of Amersham. These functions include allowing residents of the proposed development and those living in the surrounding area to use accessible natural green space, with the presence of a doctors’ surgery, and a small seed bed employment generating development, both acting as focal points in assisting the promotion of healthy living, at the same time resulting in increased social cohesion.

4.26 Further benefits attributable to the same accessible natural green space relate to opportunities for improvements to be made to biodiversity, given its location lying close to an area of open countryside. Above all, it offers those living in the locality as well as elsewhere, the opportunity to appreciate the renowned Chilterns AONB.

4.27 The area to be devoted to public open space purposes should be seen as an integral part of a mixed use development, reflecting the concept of Metroland, with buildings laid out in a spacious manner representative of the local architectural vernacular, supplemented by additional trees and hedge planting. It should be seen as part of a closed loop ecosystem, at the same time offering an opportunity for sustainable urban drainage and assisting in ground water recharge in an area possessing chalk streams and aquifers.

4.28 The use of Market Reading Field as a mixed use SUE would not adversely affect those features representative of the natural beauty of the Chilterns AONB landscape, as set out in the Chilterns Area of Outstanding Natural Beauty Management Plan 2014-2019, neither would it impact upon its natural and cultural heritage, a conclusion which is in contrast to the land forming part of Quill Hall Farm, when assessing the impact of the proposed development on the same designated landscape.

4.29 The Chilterns AONB and surrounding areas are facing pressure to accommodate a significant number of new houses, along with other much needed development; and this requires particular regard being paid to the scale of developments and their impact on the setting of the same designated landscape. The retention of open space and the need to restrict the scale of new development are key components in

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conserving the natural beauty of an AONB, with new green infrastructure providing an important role in alleviating some of the pressures from existing development in a pleasant environment.

4.30 Market Reading Field is of a size, particularly when seen in terms of its developable area, which will meet those principal characteristics commensurate with the landscape and scenic beauty for which the Chilterns AONB is known, at a scale which would avoid having a harmful impact on its setting.

4.31 Paragraph 116 of the NPPF states that planning permission should be refused for major developments in these designated areas except in exceptional circumstances, and where it can be demonstrated they are in the public interest; before setting out three points which should be assessed as part of the consideration of any proposal. There is no policy advice differentiating potential sites on the basis of their size and character, when considering whether they constitute a “major development” in an AONB. The decision maker is required to take into account the proposal in its local context.

4.32 If it is contended that the current proposals comprise a “major development” in the Chilterns AONB, then these representations have shown that when assessed against (i) the need for development; (ii) the cost of and scope of developing elsewhere; and (iii) any detrimental effect on the environment or landscape and the scope for mitigation; there are exceptional circumstances justifying the allocation of Market Reading Field for a mixed use development in the emerging Chiltern and South Bucks Local Plan.

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