Eton and Eton Wick Neighbourhood Development Plan 2016-2036

Plan Making Submitted to Submitted by Eton Town Council AECOM Aldgate Tower April 2017 2 Leman Street London, E1 8FA

Basic Conditions Statement

April 2017

AECOM Basic Conditions Statement – 2 Eton Town Council

Limitations

AECOM Infrastructure & Environment UK Limited (“AECOM”) has prepared this Report for the sole use of Eton Town Council (“Client”) in accordance with the Agreement under which our services were performed. No other warranty, expressed or implied, is made as to the professional advice included in this Report or any other services provided by AECOM. Where the conclusions and recommendations contained in this Report are based upon information provided by others it is upon the assumption that all relevant information has been provided by those parties from whom it has been requested and that such information is accurate. Information obtained by AECOM has not been independently verified by AECOM, unless otherwise stated in the Report. The methodology adopted and the sources of information used by AECOM in providing its services are outlined in this Report. The work described in this Report was undertaken in the period January 2017 to February 2017 and is based on the conditions encountered and the information available during the said period of time. The scope of this Report and the services are accordingly factually limited by these circumstances. Where assessments of works or costs identified in this Report are made, such assessments are based upon the information available at the time and where appropriate are subject to further investigations or information which may become available. AECOM disclaim any undertaking or obligation to advise any person of any change in any matter affecting the Report, which may come or be brought to AECOM’s attention after the date of the Report. Certain statements made in the Report that are not historical facts may constitute estimates, projections or other forward- looking statements and even though they are based on reasonable assumptions as of the date of the Report, such forward- looking statements by their nature involve risks and uncertainties that could cause actual results to differ materially from the results predicted. AECOM specifically does not guarantee or warrant any estimate or projections contained in this Report. Where field investigations are carried out, these have been restricted to a level of detail required to meet the stated objectives of the services. The results of any measurements taken may vary spatially or with time and further confirmatory measurements should be made after any significant delay in issuing this Report.

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Table of Contents

1 Introduction ...... 4 2 Conformity with National Planning Policy ...... 6 3 Contributing to Achieving Sustainable Development...... 12 4 General Conformity with the Development Plan ...... 16 5 Compatibility with EU Legislation ...... 18 6 Conclusion ...... 20 Appendix 1: Confirmation that SEA and HRA is not required ...... 21

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1 Introduction

1.1. This Statement has been prepared for Eton Town Council (“the Town Council”) to accompany its submission to the local planning authority, The Royal Borough of Windsor and Maidenhead (RBWM), of the Eton Neighbourhood Development Plan 2016-2036 under Regulation 15 of the Neighbourhood Planning (General) Regulations 2012 (“the Regulations”).

1.2. In accordance with section 38A and 38B of the Planning and Compulsory Purchase Act 2004, the Eton Neighbourhood Development Plan (“NDP”) has been prepared by the Town Council, the designated qualifying body, for the Neighbourhood Area covering the whole of Eton and Eton Wick, as designated by RBWM on 14th October 2013. The proposed neighbourhood plan period is to take effect from 2016 to 2036, and relates only to one neighbourhood area, the Eton neighbourhood plan area1 (comprising the Wards of Eton Wick, Eton and Castle). The NP area does not cover all of Eton and Castle Ward.

1.3. The NDP sets out policies in relation to the development and use of land, that include policies that promote healthy communities, conserve and enhance the natural environment, support and build a strong, competitive economy, and require good design in the delivery of new development and housing to meet the needs of the community. These policies are to be used in the determination of planning applications, and do not relate to excluded development.

1.4. The Statement addresses each of the five ‘basic conditions’ required by the Neighbourhood Planning Regulations and explains how the submitted Neighbourhood Plan meets the requirements of paragraph 8 of Schedule 4B to the 1990 Town & Country Planning Act.

1.5. The Regulations state that a Neighbourhood Plan will be considered to have met the basic conditions if:

a) having regard to national policies and advice contained in guidance issued by the Secretary of State it is appropriate to make the neighbourhood plan (see Section 2 of this statement)

b) the making of the neighbourhood plan contributes to the achievement of sustainable development (see Section 3)

c) the making of the neighbourhood plan is in general conformity with the strategic policies contained in the development plan for the area of the authority (or any part of that area) (see Section 4)

d) the making of the neighbourhood plan does not breach, and is otherwise compatible with, EU obligations (see Section 5)

e) prescribed conditions are met in relation to the plan and prescribed matters have been complied with in connection with the proposal for the neighbourhood plan (see Section 6)

1 See Appendix A of the Eton Neighbourhood Plan Designation Application. Accessed at: https://www3.rbwm.gov.uk/download/downloads/id/598/eton_neighbourhood_plan_designation_application.pdf

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1.7. The Town Council confirms that this neighbourhood plan:

. relates only to the Parish of Eton and Eton Wick and to no other Neighbourhood Areas; and,

. is the only Neighbourhood Development Plan in the designated area. No other Neighbourhood Development Plan exists nor is in development for part or all of the designated area.

1.8. Eton town and Eton Wick village are located in the RBWM. The majority of the policies in the Plan concern the town of Eton and village of Eton Wick, but there is a significant amount of farmland, Common land and Lammas land that makes up the hinterland of the two settlements. The area is distinguished by the Thames (the associated floodplain) and valued built heritage, such as Eton College. Such factors limit the amount of developable land and require a sympathetic approach from new developments. The map in Figure 1 shows the parish and neighbourhood plan boundary.

Figure 1. Neighbourhood Plan Boundary.

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2 Conformity with National Planning Policy

2.1. The NDP has been prepared with regard to national policies as set out in the National Planning Policy Framework (NPPF) of April 2012. It is also mindful of the national Planning Practice Guidance (PPG) first published by the Government in website format in March 2014 in respect of formulating neighbourhood plans and other relevant guidance insofar as it relates to the content of the Neighbourhood Plan. Table 1 demonstrates how policy within the NPPF has been addressed in the NDP. The NDP references national policy, where appropriate, in the supporting reasoned justification text for the various plan policies. The principles of the NPPF have been embodied throughout the development of the Neighbourhood Plan, as evidenced in Table 1.

2.2. The presence of Eton College, the numerous designated and non-designated heritage assets, the Common land and Lammas land, and the River Thames and associated flood plain encapsulate the unique characteristics of Eton and Eton Wick. As such this statement closely follows the themes that run through the plan’s vision and objectives. It therefore follows that the policies in the NPPF and Local Plan highlighted are the most pertinent to the neighbourhood area.

2.3. The below table seeks to compare the sustainability policies of the NPPF with those of the submitted NDP.

Table 1 NDP policy conformity with the NPPF

NPPF Sustainability Policy NDP Response Building a strong, competitive economy The NDP supports this policy through policies The NPPF (paragraph 21) requires that planning BL2-BL4 (Eton High Street, Eton Wick Local policies should recognise and seek to address Centre, Meanwhile uses), policy TI4 potential barriers to investment, including a poor (Telecommunication Coverage) and the projects environment or any lack of infrastructure, services or listed within chapter 7 (Delivery and housing by: Implementation) which seek to boost the local i. facilitating flexible working practices; economy e.g. Eton Visitor Centre. The policies, ii. supporting existing business sectors, taking in combination, seek to support the local account of whether they are expanding or economy by positively encouraging new contracting and, where possible, identify and plan for commercial developments. new or emerging sectors likely to locate in their area; iv. planning positively for the location, promotion and expansion of clusters or networks of knowledge driven, creative or high technology industries; and v. facilitating flexible working practices such as the integration of residential and commercial uses within the same unit. Ensuring the vitality of town centres Policies BL2 and BL3 (Eton High Street and This NPPF policy has particular relevance to towns Eton Wick Local Centre) aim to support the two or large villages with a recognised centre. Eton and centres so that they can continue to function as Eton Wick are designated as Local Centres. viable retail areas in addition to support for other Several provisions of the policy apply to Eton and appropriate commercial, leisure and community Eton Wick, such as: uses. - making clear which uses will be permitted and Policies BL3 and BL5 (Eton Wick Local Centre

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NPPF Sustainability Policy NDP Response recognition that centres are the heart of their and Healthcare Provision in Eton Wick) and communities and so plans should pursue policies to policies TI1-4 (Sustainable Transport Network, support their viability and vitality; Car Parking, Bicycle Parking, - requirement that development is well connected to Telecommunication Coverage) seek to ensure services; and development is well connected to local services. - recognition that residential development can play The plan seeks to reinforce Eton Town as a an important role in ensuring the vitality of centres. centre for local residents, visitors and tourists alike. For Eton Wick, the plan recognises the importance that the centre provides for serving a more local function for convenience and services. The NDP supports the principle of delivery of new housing in policies HD1 – HD4 (Housing Type and Location, Housing Infill and Extension, Development within Eton and Development within Eton Wick). These policies reflect the needs of the community and require new planning applications to take into account local design and focusing development on to previously developed land. New commercial development should equally enhance the sense of place and reinforce the area’s visitor economy. As such policies HD3-4 (Development within Eton and Development within Eton Wick) and policies BL1-3 (Retail, Eton High Street, Eton Wick Local Centre), alongside the priority projects (included in chapter 7), aim to enshrine heritage and design considerations into efforts to boost the local economy. Supporting a prosperous rural economy As discussed above, the NDP supports this The NPPF states that neighbourhood plans should: through policies BL2-4 (Eton High Street, Eton i. promote the retention and development of local Wick Local Centre and Meanwhile uses). In services and community facilities in villages, such as addition, policy EN2 (Local Green Spaces local shops, meeting places, sports venues, cultural Designations) supports applications for buildings, public houses and places of worship, temporary structures where they are for local (Paragraph 28); and events and fairs, or other large outdoor ii. support the sustainable growth and expansion of congregations which benefit the local all types of business and enterprise in rural areas. community/economy. Similarly, the identified projects in chapter 7 will improve Eton’s tourism offer and Eton Wick’s community facilities. This approach is consistent with these national policy aims e.g. Eton visitor centre, Community Centre/Café in Eton Wick, green infrastructure projects and pedestrian/cycling wayfinding.

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NPPF Sustainability Policy NDP Response Promoting sustainable transport The NDP explicitly supports this through policies The NPPF states ‘The transport system needs to be TI1 and TI3 (Sustainable Transport Network and balanced in favour of sustainable transport modes, Bicycle Parking) and policy EN1 (Green and giving people a real choice about how they travel. blue infrastructure). These policies seek to However, the Government recognises that different conserve, improve and expand cycle ways, policies and measures will be required in different footpaths and cycle parking (e.g. segregate communities and opportunities to maximise cyclists from motorists, minimise pedestrian- sustainable transport solutions will vary from urban cyclist interactions and widening of existing to rural areas’, (Paragraph 29). shared cyclist and pedestrian pathways and Plans should protect and exploit opportunities for the supports road improvements that enhance use of sustainable transport modes for the pedestrian priority and public transport). The movement of goods or people. Therefore, plan also supports expansion of green links and developments should be located and designed retention of well-established green corridors. where practical to accommodate the efficient Eton High Street plays a vital role for commerce, delivery of goods and supplies; including short term parking for customers and . give priority to pedestrian and cycle deliveries. A balance has been sought in the movements, and have access to high quality plan that seeks to conserve the current road public transport facilities; and, layout whilst encouraging more sustainable . create safe and secure layouts which modes of transport. minimise conflicts between traffic and cyclists Allied to this there are a series of priority or pedestrians, avoiding street clutter and projects (chapter 7) which seek to proactively where appropriate establishing home zones. implement the policy aims of the NPPF and NDP: Bus service provision to and from Eton Wick; Seek solutions for Eton and Eton Wick to address traffic volumes, pollution and safety issues; Bicycle Wayfinding; and Establish sufficient, appropriate bike parking in Eton and Eton Wick. Supporting high quality communications Policy TI4 (Telecommunication coverage) infrastructure supports applications for new mobile phone The NPPF notes that ‘Advanced, high quality masts which address network coverage issues communications infrastructure is essential for within the plan area. sustainable economic growth. The development of high speed broadband technology and other communications networks also plays a vital role in enhancing the provision of local community facilities and services’.

Delivering a wide choice of high quality homes The NDP supports this policy through policies Paragraph 50 requires delivery of a wide choice of HD1 – HD4 (Housing Type and Location, high quality homes, widening opportunities for home Housing Infill and Extension, Development ownership and the creation of sustainable, inclusive within Eton and Development within Eton Wick). and mixed communities. New residential development should enhance Paragraph 55 of the NPPF requires plans to the sense of place and create livable promote sustainable development in rural areas, neighbourhoods. As such policies HD3-4 housing should be located where it will enhance or (Development within Eton and Development maintain the vitality of rural communities. within Eton Wick) and EN3 (Flooding) aim to enshrine heritage and design considerations

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NPPF Sustainability Policy NDP Response into new developments and redevelopments. Requiring good design The NDP supports this through policies HD1- The NPPF states ‘Good design is a key aspect of HD5 (Housing Type and Location, Housing Infill sustainable development, is indivisible from good and Extension, Development within Eton, planning, and should contribute positively to making Development within Eton Wick, Local views to places better for people’, (Paragraph 56) and Historic Buildings and Landscapes) and BL1 requires: (Retail). Added design guidance is included in i. that neighbourhood plans develop robust and Appendix 1 Eton Design Guidance; Appendix 2 comprehensive policies that set out the quality of Local views of historic buildings and landmarks; development that will be expected for the area; Appendix 3 Shopfront design guidance; and ii. that developments establish a strong sense of Appendix 4 Colour Palette. place, respond to local character and history and This content ensures new development must promote or reinforce local distinctiveness create safe take into account relationships between and accessible environments where crime and buildings, landscape and open spaces which disorder, are visually attractive as a result of good are characteristic of the area and surrounding architecture and appropriate landscaping; buildings. Development must respect the local iii. that local planning authorities should not refuse vernacular, materials and, the existing planning permission for buildings or infrastructure streetscape, heights, massing and building lines which promote high levels of sustainability because of adjoining buildings. of concerns about incompatibility with an existing townscape, if those concerns have been mitigated by good design. Promoting healthy communities Eton and Eton Wick benefit from the presence NPPF policies to promote healthy communities of the Thames, Common land and Lammas include: land. These natural assets bring with them i. creating safe and accessible developments, associated leisure and mental wellbeing benefits containing clear and legible pedestrian routes, and related to use of the river and visual amenity high quality public space, which encourage the afforded by the river frontage and views of the active and continual use of public areas; area. The NDP supports this national policy by: ii. guarding against the unnecessary loss of valued . considering the impact of housing facilities and services, particularly where this would development on the community HD1 (iv) reduce the community’s ability to meet its day-to-day and HD6 (Housing Type and Location needs; and Basement Building) iii. delivery of the social, recreational and cultural . promoting green infrastructure and facilities and services the community needs, such as protecting existing green spaces (EN1 the provision and use of shared space and and 2); community facilities; and . Supporting existing community facilities iv. promotion and protection of access to high quality (implicit throughout the plan and existing open spaces for opportunities for sport and facilities identified in Appendix 6) and recreation. new facilities including medical provision in Eton Wick which has none at present and (BL5) and other leisure and community uses (BL3); . Resisting less healthy uses in sensitive locations (BL2 iv); . Maintaining and improving access to the countryside (footpaths, cycle paths, etc) in policy TI1 and EN1; and . Identifying social, green and physical

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NPPF Sustainability Policy NDP Response infrastructure that would help foster healthy living e.g. bicycle wayfinding (chapter 7). Protecting Green Belt land Policies HD4 and HD5 seek to maintain The NPPF requires that Green Belts are protected openness for a number of sensitive areas in the from inappropriate or otherwise harmful neighbourhood area; such an approach is development. consistent with national Green Belt policy. 81. Once Green Belts have been defined, local The plan’s vision, objectives, environmental planning authorities should plan positively to policies and green infrastructure projects enhance the beneficial use of the Green Belt, such (including content related to Lammas land and as looking for opportunities to provide access; to Common land) help to deliver the policy provide opportunities for outdoor sport and requirements for Green Belt, in particular recreation; to retain and enhance landscapes, visual paragraph 81 of the NPPF. The design policies amenity and biodiversity; or to improve damaged within the plan also ensure that the and derelict land. environmental and landscape context of the surrounding built and natural environments is adequately considered by applicants. Meeting the challenge of climate change, Flooding is a critical issue locally. The River flooding and coastal change Thames forms the southern boundary of the The NPPF states ‘Planning plays a key role in neighborhood area. The area includes large helping shape places to secure radical reductions in swathes of flood zone 2 and 3. Policy EN3 greenhouse gas emissions, minimising vulnerability (Flooding) takes the fluvial floodplain into and providing resilience to the impacts of climate account, in addition to pluvial and sewer change…and associated infrastructure. This is flooding. The provisions in the policy also central to the economic, social and environmental ensure that climate change is adequately dimensions of sustainable development’, (Paragraph considered, including provision of SUDS. 93). Otherwise the NDP supports this policy by: New development should be planned to avoid . Reducing harmful emissions by increased vulnerability to the range of impacts promoting sustainable methods of arising from climate change. When new transport (TI1 and 3); development is brought forward in areas which are . Identifying projects that seek traffic vulnerable, care should be taken to ensure that risks solutions for Eton and Eton Wick to can be managed through suitable adaptation address traffic volumes and associated measures, including through the planning of green pollution issues (chapter 7); and infrastructure. . Protecting green spaces and promoting Paragraph 100 states that: Inappropriate a positive approach to blue and green development in areas at risk of flooding should be infrastructure (EN 1 and 2). avoided by directing development away from areas at highest risk, but where development is necessary, making it safe without increasing flood risk elsewhere. Conserving and enhancing the natural The NDP supports this principle in policy EN1 environment by: The NPPF requires the planning system should . Supporting green corridors and features contribute to and enhance the natural and local of the landscape, including historic environment by: landmarks such as mature trees, i. protecting and enhancing valued landscapes, soils species-rich hedgerows and ponds; and the best agricultural land; . Maintaining community access and ii. minimising impacts on biodiversity; environmental integrity (development

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NPPF Sustainability Policy NDP Response iii. re-using and remediating previously developed within an 8m buffer zone from streams (brownfield) land; and 5m from historic hedgerows will not iv. minimising pollution of all kinds; and be permitted except in exceptional v. encouraging good design. circumstances); . Policies EN2 (Local Green Space Designations) and EN3 (Flooding) also help to demonstrate conformity with this national policy approach. Policies HD1-5 encourages development on brownfield land and seek to protect values landscapes. Conserving and enhancing the historic The neighbourhood area includes Listed environment Buildings and a Conservation Area. As such The NPPF requires a positive approach to ‘the heritage policies feature prominently within the conservation and enjoyment of the historic NDP. environment, including heritage assets most at risk The NDP supports this national policy primarily through neglect, decay or other threats’. through policies HD3 and 5 (Development within Eton and Local views to Historic Buildings and Landscapes) and in combination with BL1 (Retail) and all associated appendices (Appendix 1 Eton Design Guidance; Appendix 2 Local views of historic buildings and landmarks; Appendix 3 Shopfront design guidance; and Appendix 4 Colour Palette).

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3 Contributing to Achieving Sustainable Development

3.1. The central theme of the NPPF is the presumption in favour of sustainable development. In this context sustainable development is broadly defined internationally2 as meeting the needs of the present without compromising the ability of future generations to meet their own needs.

3.2. The NPPF uses three ‘dimensions’ to describe sustainable development: economic, social and environmental, and requires the planning system, and thus the NDP, where appropriate:

. to contribute to building a strong, responsive and competitive economy, by ensuring that sufficient land of the right type is available in the right places and at the right time to support growth and by improving the local supporting infrastructure.

. to support strong, vibrant and healthy communities, by providing the supply of housing required to meet the needs of present and future generations; and by creating a high quality built environment, with accessible local services that reflect the community’s needs and support its health, social and cultural well-being; and

. to contribute to protecting and enhancing the natural, built and historic environment; helping to improve biodiversity, making better use of natural resources, minimising waste and pollution, and mitigating and adapting to climate change including moving to a low carbon economy.

3.3. The NDP’s contribution to sustainable development (as defined in the NPPF) has therefore to be measured against of three dimensions (NPPF paragraph 7):

. an economic role - to contribute to building a strong, responsive and competitive economy,

. a social role - to support strong, vibrant and healthy communities; and

. an environmental role - to contribute to protecting and enhancing the natural, built and historic environment.

3.4. Table 2 shows the alignment of the NDP with the aims of the NPPF for the delivery of economic sustainability.

Table 2 Contribution of the NDP to achieving economic sustainability

Delivering Economic Sustainability

NPPF Definition Contribute to building a strong, responsive and competitive economy, by ensuring that sufficient land of the right type is available in the right places and at the right time to support growth and innovation; and by identifying and co-ordinating development requirements, including the provision of infrastructure. NDP Objectives 1 Create sustainable parameters and foster design to ensure that new development is suitable for the local area, particularly in areas of high heritage value. 2 Conserve the heritage character of the area, including the streetscapes and historic countryside surrounding Eton and Eton Wick by ensuring the plan policies promote the conservation and enjoyment of the neighbourhood’s historic environment, including its designated and non-designated

2 Resolution 24/187 of the United Nations General Assembly

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Delivering Economic Sustainability

heritage assets, in a manner appropriate to their significance 3 Protect and support the different roles that commercial and retail businesses play in Eton and Eton Wick. 4 Revitalise the centre of Eton Wick for pedestrians including shopping and open space aspects, respecting the rural nature of the village. 5 Support the continued evolution of Eton College as a world class educational establishment consistent with the vision. 6 Support access improvements between Eton Wick and Eton including sustainable transport methods. 7 Facilitate solutions that contribute to traffic, pollution and safety improvements at Keate’s Lane Junction in Eton. 8 Encourage improvements to mobile phone connectivity. 9 Enhance our community and public infrastructure to improve the lives of our community and visitors, including supporting healthcare provision in Eton Wick. NDP Policies HD1: Housing Type and Location HD2: Housing Infill and Extension HD3: Development within Eton HD4: Development within Eton Wick BL1: Retail BL2: Eton High Street BL3: Eton Wick Local Centre BL4: Meanwhile uses BL5: Healthcare Provision in Eton Wick TI1: Sustainable Transport Network TI2: Car Parking TI3: Bicycle Parking TI4: Telecommunication Coverage Commentary These NDP policies contribute to economic sustainability by: . Supporting the development of additional housing; . improving opportunities for home-based working via improvements to communications; . supporting the continued development of existing commercial and academic areas; and . encouraging improvements that would assist the visitor and tourism economy.

3.5. Table 3 shows the alignment of the NDP with the aims of the NPPF for the delivery of social sustainability.

Table 3 Contribution of the NDP to achieving social sustainability

Delivering Social Sustainability

NPPF Definition Support strong, vibrant and healthy communities, by providing the supply of housing required to meet the needs of present and future generations; and by creating a high quality built environment, with accessible local services that reflect the community’s needs and support its health, social and cultural well-being.

NDP Objectives 1 Create sustainable parameters and foster design to ensure that new development is suitable for the local area, particularly in areas of high heritage value. 2 Conserve the heritage character of the area, including the streetscapes and historic countryside surrounding Eton and Eton Wick by ensuring the plan policies promote the conservation and enjoyment of the neighbourhood’s historic environment, including its designated and non-designated heritage assets, in a manner appropriate to their significance 4 Revitalise the centre of Eton Wick for pedestrians including shopping and open space aspects, respecting the rural nature of the village. 6 Support access improvements between Eton Wick and Eton including sustainable transport methods.

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Delivering Social Sustainability

7 Facilitate solutions that contribute to traffic, pollution and safety improvements at Keate’s Lane Junction in Eton. 9 Enhance our community and public infrastructure to improve the lives of our community and visitors, including supporting healthcare provision in Eton Wick. 11 Mitigate flood risks that new development might impose, and improve drainage and sanitation in the neighbourhood plan area. NDP Policies HD1: Housing Type and Location HD2: Housing Infill and Extension HD3: Development within Eton HD4: Development within Eton Wick HD6: Basement Building BL2: Eton High Street BL3: Eton Wick Local Centre BL5: Healthcare Provision in Eton Wick TI1: Sustainable Transport Network TI3: Bicycle Parking TI4: Telecommunication Coverage Commentary These NDP policies contribute to social sustainability by: . ensuring development will not have a detrimental impact upon the quality of life of residents; . actively seeking a suitable site for a new health facility; . supporting the development and expansion of new community facilities; and . improving access to open spaces and community safety by improving footpaths, cycle paths, signage and projects to seek traffic calming measures.

3.6. Table 4 shows the alignment of the NDP with the aims of the NPPF for the delivery of environmental sustainability.

Table 4 Contribution of the NDP to achieving environmental sustainability

Delivering Environmental Sustainability

NPPF Definition Contribute to protecting and enhancing our natural, built and historic environment; and, as part of this, helping to improve biodiversity, use natural resources prudently, minimise waste and pollution, and mitigate and adapt to climate change including moving to a low carbon economy.

NDP Objective 1 Create sustainable parameters and foster design to ensure that new development is suitable for the local area, particularly in areas of high heritage value. 2 Conserve the heritage character of the area, including the streetscapes and historic countryside surrounding Eton and Eton Wick by ensuring the plan policies promote the conservation and enjoyment of the neighbourhood’s historic environment, including its designated and non-designated heritage assets, in a manner appropriate to their significance 4 Revitalise the centre of Eton Wick for pedestrians including shopping and open space aspects, respecting the rural nature of the village. 6 Support access improvements between Eton Wick and Eton including sustainable transport methods. 7 Facilitate solutions that contribute to traffic, pollution and safety improvements at Keate’s Lane Junction in Eton. 10 Conserve the natural environmental and promote improvements to green and blue infrastructure (including historic hedgerows, meadows, and watercourses). 11 Mitigate flood risks that new development might impose, and improve drainage and sanitation in the neighbourhood plan area. 12 Encourage the design and planting of new habitats where appropriate.

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Delivering Environmental Sustainability

NDP Policies HD1: Housing Type and Location HD2: Housing Infill and Extension HD3: Development within Eton HD4: Development within Eton Wick HD5: Local views to Historic Buildings and Landscapes HD6: Basement Building BL1: Retail BL5: Healthcare Provision in Eton Wick TI1: Sustainable Transport Network TI3: Bicycle Parking EN1: Green and blue infrastructure EN2: Local Green Space Designations EN3: Flooding Commentary These NDP policies contribute to environmental sustainability by: . considering the impact of housing development on the form, character and setting of settlement and local environment; . requiring that development respects the delicate balance between buildings, views, landscape and opens spaces; . protecting green spaces, maintaining existing habitats and creating new green infrastructure; . providing increased and safer access to the countryside; . requiring development to mitigate against the risk of flooding on and off site and, . providing suitable drainage (e.g. SUDS) for residential development.

3.7. In short, the NDP contributes to the achievement of sustainable development by:

. including policies that ensure commercial and residential development adequately reflect the unique characteristics of the local area (the River Thames, local heritage assets, Lammas land, Common land) to ensure natural and built heritage assets are protected and development is delivered in accordance with high quality design principles and adequate regard to urban drainage and wider infrastructure considerations; . protecting and enhancing the built and historic environment of Eton and Eton Wick by encouraging high quality development that responds to the local vernacular, form, character and setting of the town, village and surrounding local environment; . supporting improvements to the local economy and visitors/tourists in the neighbourhood area by encouraging commercial opportunities in Eton Town; . revitalising Eton Wick Local Centre by seeking to improve the community facilities, leisure and retail offer; . protecting green space, local habitats and opportunities to provide biodiversity gains within new developments; . protecting community assets that both enhance the quality of life in the town and village and establishing projects that provide new facilities; . implementing projects that seek to maintain or improve access (footpaths, cycle paths), minimise traffic problems, segregate vehicles and people (where practical) and maintain highways access for businesses; and

. protecting blue infrastructure (e.g. River Thames) and requiring development to be designed to minimise flood risk (on and off site).

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4 General Conformity with the Development Plan

4.1. The National Planning Practice Guidance states that a draft neighbourhood plan must be in general conformity with the strategic policies of the development plan in force if it is to meet the basic condition. Although a draft Neighbourhood Plan is not tested against the policies in an emerging Local Plan the reasoning and evidence informing the Local Plan process is likely to be relevant to the consideration of the basic conditions against which a neighbourhood plan is tested. Therefore up-to-date evidence prepared for the Local Plan should be fed into the formulation of a Neighbourhood Plan, where relevant. The NDP takes into account relevant Local Plan evidence base, such as the:

. RBWM Strategic Flood Risk Assessment 2014;

. RBWM Retail and Town Centre Study 2015;

. Berkshire Strategic Housing Market Assessment 2016; and the

. Eton Conservation Area Appraisal 2009.

4.2. The NDP must demonstrate that it is in general conformity with the RBWM development plan for the area (or any part of that area). The submitted NDP is in general conformity with the relevant strategic policies contained in RBWM’s extant Local Plan 2003.

4.3. A new Borough Local Plan (BLP) is also being prepared for the period 2013-2033, which will update saved policies in the RBWM Local Plan 2003 and include new policies arising in response to new evidence and new national policy and guidance (within the NPPF and Planning Practice Guidance). Throughout the NDP’s development a close dialogue was kept with RBWM to ensure that the NDP’s policies were in general conformity with the existing Local Plan, but also, that they would not be in conflict with the policies of the emerging BLP.

4.4. The polices contained in the NDP are considered to be consistent with the following strategic policies of the extant RBWM Local Plan (Incorporating Alterations Adopted June 2003)3:

. GB 1 Acceptable uses and development in the Green Belt . N 1 Areas of Special Landscape Importance . N 2 Setting of the Thames . N 4 Common land, Village Greens and Ponds . DG 1 Design guidelines . TEL 1 Telecommunications Development . F 1 Development within areas liable to flood . NAP 3 Polluting development . NAP 4 Pollution of groundwater and surface water . R 1 Protection of Urban Open Spaces . CF 1 Protection of existing facilities . CF 2 Provision of new facilities . S 1 Location of shopping development . H 2 Identified housing sites . H 3 Affordable housing within urban areas . H 4 Affordable housing within rural areas

3 As set out in a RBWM Development Plan Policy Schedule (dated 27 September 2011)

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. H 6 Town centre housing . H 8 Meeting a range of housing needs . H 9 Meeting a range of housing needs . H 10 Housing layout and design . T 5 New Developments and Highway Design . T 7 Cycling . T 8 Pedestrian environment . T 10 Public transport . ETN 1 Protection of the retail role . ETN 2 Restraint on business development . IMP 1 Associated infrastructure, facilities, amenities

4.5. The polices contained in the NDP are considered to be consistent with the following emerging policies of the RBWM BLP:

. SP1 Spatial Strategy . SP3 Design . SP4 Townscape and Landscape . SP5 River Thames Corridor . SP6 Development in the Green Belt . SP7 Countryside Character . HO1 Housing Development Sites . HO2 Meeting Housing Need . HO3 Affordable Housing . HO5 Housing Layout and Design . ED1 Economic Development . TR1 Hierarchy of Centres . NR1 Sustainable Design and Construction . NR3 Managing Flood Risk and Waterways . EP1 Environmental Protection . NE4 Open Space . IF1 Community facilities . IF3 Sustainable Transport . IF4 Infrastructure and Developer Contributions . IF5 Telecommunications . IF6 Water Supply and Sewerage Infrastructure

4.6. The remaining saved RBWM 2003 Local Plan Policies are either site specific and do not apply to the NDP or they are not strategic in nature.

4.7. The NDP is in general conformity with the RBWM development plan adding value to local plan policy that can be easily considered alongside the development plan and any other material considerations in determining planning applications.

AECOM Basic Conditions Statement – 18 Eton Town Council

5 Compatibility with EU Legislation

5.1. The Neighbourhood Plan has regard to the fundamental rights and freedoms guaranteed under the European Convention on Human Rights and complies with the Human Rights Act 1998. The plan sought to consult across the community broadly including groups older people, younger people and ‘hard to reach groups’.

5.2. As the NDP does not include policies to allocate sites for development or include policies that are likely to have significant environmental effects on European protected sites, the local and wider environment, there was not a requirement for the NDP to prepare a Strategic Environmental Assessment (SEA) in accordance with EU Directive 2001/42 on SEA as outlined in the screening opinion confirmed by RBWM in agreement with statutory consultees.

5.3. Section 11 of the Environmental Assessment of Plans and Programmes Regulations 2004 requires RBWM to determine whether the NDP is likely to have significant environmental effects. RBWM Council has determined after consultation with Natural England, the Environment Agency and Historic England that the NDP is not likely to have significant environmental effects and, therefore, a Strategic Environmental Assessment (SEA) is not required (see Appendix 1).

5.4. In addition to the screening of Neighbourhood Plans in relation to SEA, there is a need to assess the likelihood of proposals within a Plan having an adverse impact on internationally designated wildlife sites. This Habitats Regulations Assessment (HRA) is required by the European Habitats Directive. A Habitats Regulations Assessment may be required depending on the contents of the Neighbourhood Plan and the potential impact of the Plan on internationally designated wildlife sites within a reasonable distance from the Neighbourhood Plan area. For the purposes of assessment this will be taken to be sites within 20km of the Neighbourhood Area.

5.5. The neighbourhood area is situated outside any European Designated Protection Area. European sites (sometimes known as ‘Natura 2000’ sites / network and Ramsar sites) include candidate (SPA) Special Areas of Conservation (SAC), Sites of Community Importance, Special Areas of Conservation and Special Protection Areas, and is defined in regulation 8 of the Conservation of Habitats and Species Regulations 2010.

5.6. The BLP HRA Screening identified that only designated sites within 5km were likely to suffer adverse effects from the plan. Of the sites identified, Windsor Forest and Great Park SAC is within 2 kilometres of the plan area whilst an SPA is within 5km of parts of the plan area. All others are further than 5km from the plan’s boundary and can be discounted in terms of likely effects.

5.7. Following a HRA screening determination undertaken by RBWM Council it as found that the Eton and Eton Wick Neighbourhood Plan will not have an adverse effect on the integrity of internationally designated sites either on its own or in combination with other plans and does not need to be subject to a Habitats Regulations Assessment.

5.8. Policies within the NDP require development to protect, enhance and improve the built and natural environment within the plan area, providing it does not negatively impact on people and neighbouring uses through pollution impacts.

AECOM Basic Conditions Statement – 19 Eton Town Council

5.9. There are no policies relating to loss of homes, gypsy and traveller provision, disabled access to public building or public realm. No policy discriminates on the basis of race, ethnicity, sexual orientation or religion.

AECOM Basic Conditions Statement – 20 Eton Town Council

6 Conclusion

6.1. The Basic Conditions as set out in Schedule 4B of the Town and Country Planning Act 1990 are considered to be met by the NDP. It is therefore considered that the NDP complies with Paragraph 8(1)(a) of Schedule 4B of the Act.

AECOM Basic Conditions Statement – 21 Eton Town Council

Appendix 1: Confirmation that SEA and HRA is not required

Eton and Eton Wick Reg 14 Pre-Submission Neighbourhood Plan October 16 taking into account version 2 of the plan of 7th Oct 16

SEA and HRA Screening Opinion (7th Nov 16)

An HRA Screening Report was written for the emerging RBWM Borough Local Plan (BLP) in December 2013 and consulted on in Spring 2014, this was updated and the statutory bodies were consulted again in Summer 16 for the draft Borough Local Plan. The screening report concluded that the BLP was unlikely to have significant effects on the integrity of designated sites, and that therefore a full Appropriate Assessment of the plan was not required. Consultation responses received raised some specific points but overall were in agreement with this conclusion.

The Eton and Eton Wick Neighbourhood Plan area forms a small part of the wider area examined as part of the BLP HRA Screening. The BLP HRA Screening Report therefore provides useful context for the Screening of the Eton and Eton Wick Neighbourhood Plan.

Five designated sites lie wholly or partly within the borough, namely:

• Chiltern Beechwoods SAC

• South West London Water Bodies SPA and Ramsar

• Thames Basin Heaths SPA

• Thursby, Ash, Pirbright & Chobham SAC (part of the Thames Basin Heaths SPA)

• Windsor Forest and Great Park SAC

Relevant designated sites outside the borough are:

• Broadmoor to Bagshot Heaths SSSI (part of Thames Basin Heaths SPA)

• Burnham Beeches SAC

The BLP HRA Screening identified that only designated sites within 5km were likely to suffer adverse effects from the plan. The same distance has been used for screening exercises for other neighbourhood plans in the borough. It is appropriate and consistent to use the same linear distance in the SEA / HRA Screening for the Eton and Eton Wick Neighbourhood Plan.

Of the sites identified above, Windsor Forest and Great Park SAC is within 2 kilometres of the plan area whilst an SPA is within 5km of parts of the plan area. All others are further than 5km from the plan’s boundary and can be discounted in terms of likely effects. It is therefore

AECOM Basic Conditions Statement – 22 Eton Town Council

necessary to consider whether the neighbourhood plan is likely to give rise to any effects on the SAC and SPAs.

Having examined the Eton and Eton Wick Neighbourhood Plan, my conclusion is that it will not require a full Strategic Environmental Assessment or a full Appropriate Assessment under the Habitats Regulations. This is because it is unlikely to have significant environmental effects on the SAC and SPAs. In reaching this conclusion I rely on the following facts: a) The plan does not allocate any sites for development b) The plan does not include proposals that would affect any sensitive natural or heritage assets c) The plan does not appear to lead to any significant environmental effects

Based on the above reasoning, I consider that neither a full Strategic Environmental Assessment nor a full Appropriate Assessment under the Habitats Regulations is required for the Eton and Eton Wick Neighbourhood Plan.

For Heritage Assets I consider some of the draft policies may not comply with the NPPF and may not be in accordance with current best practice to achieve the conservation of these assets that the draft Neighbourhood Plan is seeking, but, when viewed with policies in the Borough Local Plan and the NPPF they are unlikely to have an impact which would require a full Sustainability Appraisal/Strategic Environmental Assessment.

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David Carlisle, Principal Planner [email protected] AECOM Aldgate Tower 2 Leman Street London, E1 8FA