Planning Committee Wednesday 22Nd November 2017

Chilterns Conservation Board Planning Committee Wednesday 22nd November 2017

Members of the Planning Committee of the Chilterns Conservation Board for the Chilterns Area of Outstanding Natural Beauty are hereby summoned to a meeting of

Planning Committee

on 10.00 a.m. Wednesday 22nd November 2017

at The Chilterns Conservation Board office, 90 Station Road, Chinnor, OX39 4HA

Agenda

1. Apologies 10.00 – 10.01

2. Declarations of Interest 10.01 – 10.02

3. Minutes of Previous Meeting 10.02 – 10.10

4. Matters Arising 10.10 – 10.20

5. Public Question Time 10.20 – 10.30

6. New Position Statement on Cumulative Impact of Development 10.30 – 10.50

7. Independent Review of Housing in England’s AONBs 10.50 – 11.10

8. AONB Management Plan Review development section ….11.10 – 11:30

9. Development Plans responses – update 11.30 – 11.45

10. Planning Applications – update 11.45 – 12.00

11. Any urgent business 12.00 – 12.25

12. Date of Next and Future Meetings 12.25 – 12.30

Chilterns Conservation Board Planning Committee Wednesday 22nd November 2017

Item 3 Minutes of Previous Meeting

Author: Lucy Murfett Planning Officer

Lead Organisations: Chilterns Conservation Board

Resources: Budget of £500 per year for minute-taker plus staff time

Summary: Minutes of the previous meeting are attached (at Appendix 1) and require approval.

Purpose of report: To approve the Minutes of the previous meeting.

Background

1. The draft minutes from the meeting on 20th July 2017 are attached (at Appendix 1) for approval.

Recommendation

1. That the Committee approves the minutes of its meeting which took place on 20th July 2017.

Chilterns Conservation Board Planning Committee Wednesday 22nd November 2017

Appendix 1

MINUTES OF THE MEETING OF THE PLANNING COMMITTEE HELD ON Thursday 20th July 2017 at THE CHILTERNS CONSERVATION BOARD OFFICE, STATION ROAD, CHINNOR, COMMENCING AT 10.00 AM

BOARD MEMBERS PRESENT Member Appointing Body Appointed by Local Authorities Cllr Heather Kenison Three Rivers District Council Cllr Lynn Lloyd South Oxfordshire District Council Cllr Nick Rose Chiltern District Council

Appointed by the Secretary of State Helen Tuffs Secretary of State Elizabeth Wilson Secretary of State- Chair

Elected by Parish Councils Cllr Alison Balfour-Lynn Hertfordshire Cllr Sue Biggs Oxfordshire

Officers present- Helen Hall Programme Manager Chilterns AONB HS2 Review Group Lucy Murfett CCB Planning Officer Mike Stubbs CCB Planning Advisor

And others Esther Barratt Work experience student Deirdre Hansen Minute taker John Nicholls Board Member, observing

Elisabeth Wilson welcomed Esther Barratt to the meeting, an A level work experience student. The Planning Officer welcomed all present.

297. Election of Chair. Elizabeth Wilson was proposed, seconded and unanimously elected to serve as Chair until the AGM in 2018. Chilterns Conservation Board Planning Committee Wednesday 22nd November 2017

298. Apologies for absence

Apologies were received and accepted from Cllr David Barnard North Herts District Council and Colin Courtney, Secretary of State appointee.

299. Declarations of Interest Cllr Lynn Lloyd made a declaration of interest as a member of the steering Committee for the Chinnor Neighbourhood Plan item 308 Planning Applications Update.

300. Update on HS2 Detailed Design Principles Helen Hall, Programme Manager for the Chilterns HS2 Review Group gave a brief history of the establishment of the Chilterns AONB HS2 Review Group. The group’s remit includes developing detailed design principles for the stretch of HS2 through the Chilterns AONB and its setting. She gave a presentation summarising the draft Detailed Design Principles (DDP). The principles are intended to guide the Main Works Contractors in developing designs for HS2 infrastructure and to assist local authorities in assessing applications for HS2 made under the Schedule 17 process. HS2 Ltd established and fund the Review Group, and CCB officers are represented on the Group.

10.10 Alison Balfour-Lynn joined the meeting.

The Review Group is also looking at additional integration and enhancement of the distinctive and nationally recognised landscape.

10.11 Nick Rose joined the meeting.

Helen Hall reminded the Committee of the £3m for additional projects that can provide benefit for the Chilterns. The Review Group have run 2 workshops and are collecting further project ideas, which should be aligned to the purpose of the AONB. The Committee were shown examples of projects being considered. The Committee had to opportunity to ask questions and provided feedback on the draft proposals. Committee supported the involvement of the Planning Officer in the Review Group, with the aim of achieving an exemplar landscape design for the project.

1.The Committee NOTED the update and provided feedback at the meeting

The Chair thanked Helen Hall for her presentation.

301. Minutes of the previous meeting The minutes of the meeting held 1st March 2017 were approved as a true record and signed by the Chair.

302. Matters Arising from the minutes There were no matters arising not on the agenda.

303. Public Question time No members of the public were present. Chilterns Conservation Board Planning Committee Wednesday 22nd November 2017

304. Co-option of an External Professional The Committee had discussed the need for professional assistance to the Committee, there is opportunity to co-opt up to four non-Board members to the Committee. Chris Hannington, a Landscape Architect and Manager for Trees and Landscape at Wokingham Borough Council was nominated and unanimously approved as a co-opted, non-voting member of the Committee.

The Committee was asked to suggest other suitable professionals.

1. The Committee AGREED to co-opt Chris Hannington to the Planning Committee.

2. The Committee NOTED the other co-opted places that exist on the Planning Committee and to make suggestions.

305. Chilterns Building Design awards update. The Planning Officer reported to the Committee on the 2017 Chilterns Building Design Awards.

The Winery at Hundred Hill Vineyard, Stonor Valley, South Oxfordshire was the overall winner. The judges had felt it exemplified good vernacular design and the use of high quality materials. It sits in harmony with its setting of the vineyard and represents a significant enhancement to the site.

Highly commended: Private house, 19 Mill Lane, Old Amersham. Commended: New Build Art, Music & Resource Centre, The John Turner Building, Shiplake College Commended: Conversion of a Victorian Sawmill into Passivhaus, The Old Sawmill, Parmoor, Frieth, Bucks.

The Planning Officer commented that it had been a successful and pleasant project to be involved in jointly with the Chiltern Society.

1.The Committee NOTED the update

306. Report on Cumulative Impact of Development Work. The Planning Officer informed the Committee that a successful Planning Forum had been held on 22 March 2017 which brought together local authority planners and stakeholders to consider the issue of cumulative impact of development on the Chilterns AONB. At the Forum, it was suggested that an advice guide on Cumulative Impacts of Development on the AONB be produced for planners working on Local Plans. The Chiltern Society has offered to fund this and the draft guidance produced by Professor Riki Therivel on Assessing Cumulative Impacts on the Chilterns AONB in Sustainability Appraisals (SA/SEA) had been circulated to the Committee. The Planning Officers asked the Committee for comment on the draft. All comments to be sent to the Planning Officer. Chilterns Conservation Board Planning Committee Wednesday 22nd November 2017

The Committee commended the idea to work in this area and noted that the CCB is well placed to put this work forward.

1. The Committee NOTED the update and will send comments to the Planning Officer.

307. Development Plan Responses The Planning Officer informed the Committee that she had submitted responses on 14 consultations, including development plan documents, government consultations and infrastructure proposals affecting the AONB. She gave brief comment on the submissions made.

The DEFRA housing team had made a visit to the Chilterns AONB and the Chief Officer and the Planning Officer had taken them on a tour of some locations where housing development is proposed in the AONB and its setting.

1 The Committee APPROVED the responses that had been sent, NOTED the current consultations on development plans and provided comments to the Planning Officer as appropriate.

308. Planning Applications Update The Planning Officer informed the Committee about, and sought approval for, the 28 responses that have been made by the Planning Advisor under delegated powers in connection with Planning Applications as detailed in the agenda. The responses were discussed and particular note was made of: a. Planning applications in Chinnor - land off Crowell Road P17/S1867/FUL - land Lower Icknield Way P17/S1587/OUT - Forest Glade Kennels P17/S1268/FUL. This application has now been withdrawn. All the applications harm views of the escarpment. CCB raised comments based on landscape / visual impact pertinent to setting (Crowell and Lower Icknield Way) and objection on insensitive development harmful to special qualities (Kennels Site – application subsequently withdrawn). b. Upper Little London Farm, Wendover 17/00148/AOP. CCB objections on many points, the application is still pending a decision. c. CABI, Wallingford. CCB Objection. This application harms the special qualities of the AONB. The application to renew the 2012 consent is still pending. The 2016 application for 91 dwellings is at appeal. d. Little Sturridge Farm, Stokenchurch 17/05663/OUT. CCB objection in principle. Major development that would fail to protect and enhance the AONB landscape. e. Beaconsfield link road A355, following amendments by BCC, CCB comments on wider cumulative impacts as BCC have reduced the size of the project to delete works near Amersham end of A355.

1. The Committee NOTED and APPROVED the responses made in connection with the applications as listed. Chilterns Conservation Board Planning Committee Wednesday 22nd November 2017

309. Urgent Business a. a question was raised about rumoured development of 6500 houses at J7 M40, one of the (not-preferred by the Council) options for a new settlement in the emerging South Oxfordshire Local Plan. b. A question was asked about the progress on Rail Electrification (Goring gantries). The Planning Officer reported that an Environmental Colour expert had provided some training, and a trial to alter the colour of some gantries had been suggested. She had been informed by Network Rail that head spans were not an option under consideration. The next step is for the Overhead Line Electrification in AONBs Advisory Group to walk the route and look at gantry design adaptation and mitigation to suit the local environment, this has however been postponed. There is no further news, but Network Rail’s commitment is there.

310. Date of the next meeting Wednesday 22nd November 2017 at CCB offices at 10.00 am. Future dates: Wednesday 7th March, 18th July and 21st November 2018.

The Chair…………………………………….. Date………..

Chilterns Conservation Board Planning Committee Wednesday 22nd November 2017

Item 6 New Position Statement on Cumulative Impact of Development

Author: Lucy Murfett Planning Officer

Lead Organisations: Chilterns Conservation Board

Resources: Staff time, CCB funding for workshop, and Chiltern Society funds for the advice guide

Summary: The CCB Position Statement on the Cumulative Impacts Assessment of development has been published and is ready for circulation. Purpose of report: To report progress on the publication of the Position Statement

Background

1. The Planning Committee on 20th July received a report on the Planning Forum workshop held in March which brought together LA planners and stakeholders to consider the issues of Cumulative Impacts of Development in the AONB, and the progress on a new advice guide on CIA to be sent to all constituent LPAs. The guide has evolved into a Position Statement on Cumulative Impacts Assessment. A near-final draft of the Position Statement was discussed at the CCB Board meeting on 25 October: the Board considered and approved the draft, and agreed, subject to any changes, that it be published and circulated directly to LPAs.

2. A few minor changes have been made to that draft, and the final document is now ready for circulation. Reference has been made in the CPRE and NAAONB Independent Review of Housing in England’s AONBs 2012-2017 (see item 7) to this CIA guide.

3. The Position Statement is available via this weblink http://www.chilternsaonb.org/conservation-board/planning-development/position- statements.html

Recommendation

1. That the Committee notes the update and that members take opportunities to promote the Position Statement.

2. That the Planning Officer circulates the Position Statement to LPAs and other stakeholders.

Chilterns Conservation Board Planning Committee Wednesday 22nd November 2017

Item 7 An Independent Review of Housing in England’s Areas of Outstanding Natural Beauty 2012-2017

Author: Lucy Murfett Planning Officer

Lead Organisations: CPRE and the National Association of AONBs

Resources: CCB contribution of £1000 towards the research project. Staff time assisting with and participating in the project, and providing a case-study.

Summary: This publication contains important and valuable research on the pressures of housing development, particularly in AONBs in southern England.

Purpose of report: To alert the Committee to the contents and conclusions of the Review, and to seek support for active dissemination of its findings.

Background

1. Research was commissioned by CPRE and the NAAONB with a number of aims, including providing quantitative and qualitative evidence on the impact of decisions on housing development across the AONBs from 2012-2017; identifying actions to reduce any such negative impacts; making recommendations for strengthening the protection of AONBs; and informing any input into any review of the NPPF or Housing White Paper.

2. The report usefully reviews the policy framework for housing in rural areas, and for AONB designations. The principal findings over the period are:

• A growing number of planning applications for housing within AONBs and their settings • A growing number of applications and approvals for larger (>100 unit) sites • A step-change upwards in approvals for housing since 2015 • Housing pressure is most acute in SE and SW regions, with 8 AONBs (including Chilterns) accounting for 79% of all housing approved in AONBs.

3. For these 8 AONBs, including the Chilterns, the principal findings are in

Chilterns Conservation Board Planning Committee Wednesday 22nd November 2017

Table 4 Development within Selected AONBs 2012-2017 and pre 2012: Pre 2012 2012-2015 2015-2017 AONB Units per Units Units Units Units Units per year per per per per year 1000 average 1000 year 1000 average house- house- average house- holds holds holds Chilterns 82 1.02 138 1.72 386 4.82 Cornwall 120 2.22 192 3.55 210 3.88 Cotswolds 217 1.70 533 4.26 635 5.08 Dorset 265 3.78 280 4.00 184 2.62 High Weald 186 1.50 311 2.51 895 7.21 Kent Downs 192 2.06 145 1.55 415 4.46 N. Wessex 252 2.01 168 1.34 391 3.12 Downs South Devon 82 2.61 111 3.51 198 6.38 Surrey Hills 47 1.27 90 2.43 96 2.59 NB Note that these are only developments of 10 or more homes, so the figures including smaller schemes would be significantly higher

and Table 9: Housing pressure by selected AONB (number of housing schemes >10 units approved and number of units within AONBs and within 500m of AONBs) 2012-2017

AONB No. > 10 No. of No. of No. of units housing units schemes housing units schemes approved approved approved approved within AONB within 500m within 500m within AONB of AONB of AONB Chilterns 23 1,213 30 922 Cornwall 35 998 6 154 Cotswolds 62 2,869 41 2,968 Dorset 31 1,217 10 567 High Weald 58 2,723 33 2,253 Kent Downs 22 1,266 18 547 N. Wessex Downs 35 1,286 15 567 South Devon 23 732 6 221 Grand total 289 12,304 159 8,199 NB Note that these are only developments of 10 or more homes, so the figures including smaller schemes would be significantly higher

4. Specific references to the Chilterns in the Report include mention of the need for the larger AONBs such as Cotswolds and Chilterns to work across a large number of LPAs; the high level of housing approvals for sites which also fall within the Green Belt (Chilterns and Surrey Hills AONB); CCB’s proposed Toolkit for Neighbourhood Plans; the Chilterns Cumulative Impacts Assessment Guide (see item 7); and a case study of Handsmooth House, Ipsden. Chilterns Conservation Board Planning Committee Wednesday 22nd November 2017

5. The Report makes a number of useful recommendations, under the themes of • measures to help AONB areas respond to the national need for housing • measures to achieve a better planning balance by strengthening the weight given to the AONB purpose • measures to address capacity and support issues

6. There will be an opportunity to discuss the findings and recommendations at CCB Planning Committee.

Recommendation 1. The Planning Committee welcomes the report 2. The CCB, with the NAAONB and other AONBs, promote the findings locally and nationally 3. The conclusions of the Review are input into the work on the new Chilterns AONB Management Plan (see Item 8)

Chilterns Conservation Board Planning Committee Wednesday 22nd November 2017

Item 8 Chilterns AONB Management Plan Review Development Section

Author: Lucy Murfett Planning Officer

Lead Organisations: Chilterns Conservation Board

Resources: Staff time, Planning Committee time

Summary: A report to introduce forthcoming work on the AONB Management Plan review and discuss the approach.

Purpose of report: To update the Committee on a forthcoming new area of work.

Background

1. An AONB Management Plan has to be reviewed every five years (Countryside and Rights of Way Act 2000 section 89). The current Chilterns AONB Management Plan covers the period 2014-2019 and the process of reviewing this plan has commenced, with a notification letter being sent in October to local authorities and Natural England (under section 90 of CRoW Act), and a launch event for local authority senior officers, Natural England and DEFRA on 16th November 2017.

2. The current plan contains a chapter on Development, attached at Appendix 2. The review provides an opportunity to consider the content, policies and format of that chapter, which is proposed to be expanded to cover both Development and Transport. The relationship of this chapter with CCB’s Model Policy for the Chilterns AONB and the three Position Statements could be explored, as well as the status of the management plan and its relationship to local plans and neighbourhood plans.

3. The process will involve both workshops with experts, partners and stakeholders as well as public consultation at two stages in the plan preparation. Views are sought on whether the existing structures of Planning Committee and Planning Forum could be utilised to shape the plan.

Recommendation 1. That the Committee notes the update and provides feedback at the meeting on the best approach to reviewing the development section of the Chilterns AONB Management Plan.

Chilterns Conservation Board Planning Committee Wednesday 22nd November 2017

Appendix 2 Extract of Development Chapter of Current Chilterns AONB Management Plan

Chilterns Conservation Board Planning Committee Wednesday 22nd November 2017

Item 9 Development Plans Responses

Author: Lucy Murfett Planning Officer

Lead Organisations: Chilterns Conservation Board

Resources: Staff time

Summary: Since the papers for the last Planning Committee meeting representations have been submitted on 9 development plan documents and 3 government/ infrastructure consultations. Purpose of report: To update the Committee about development plan documents.

Recommendation 1. That the Committee approves the responses sent in Appendix 3, notes the current consultations on development plans listed in Appendix 4 and provides comments to the Planning Officer as appropriate.

Chilterns Conservation Board Planning Committee Wednesday 22nd November 2017

APPENDIX 3 CCB Responses on Development Plan Consultations:

Consultation Consulte Response – summary CCB document d by response date South and SODC 20.7.17 Vale Draft CCB warmly welcomes the new draft GI Strategy. Green Infrastructur 1. The Board supports in particular: e Strategy - the good level of focus on the AONBs - the proposal to “maximise GI opportunities arising from designated landscape - areas (AONBs) with the associated management organisations and funding structures” (page 43) - the ambition to “create bigger, more joined-up and resilient ecological networks that connect, enlarge and enhance existing habitats that create and support healthy ecosystems” (p43) - “encourage easy, no/low cost physical exercise, and mental health benefits” (p42) - “restoration of degraded landscapes through development” (p43) this accords with our Chilterns AONB Management Plan policy D11 - the arrows showing the Strategic Green Infrastructure Network are great (Figure 3.1) - the combination and South and Vale as a joint document gives it that landscape-scale which is welcomed, also gives the chance to appreciate and plan for the two adjoining AONBs (NWD and Chilterns) in a connected way.

2. The mapping is excellent. However the two-district scale means it is hard to see detail. It would be very good if these layers could be made available (zoomable, searchable) on a publicly accessible website?

3. It would be good if the conservation target area in neighbouring counties could be shown on a map to see how these relate to /connect with the CTAs in Oxfordshire eg the Bucks BOAs (Biodiversity Opportunity Areas). Habitats, links and opportunities do not stop at the administrative boundaries.

4. Equally it would helpful if the role of the AONBs in providing a regional network of protected landscapes and “room to breathe” around the capital London was acknowledged, see the recent report on this concept entitled The Protected Chilterns Conservation Board Planning Committee Wednesday 22nd November 2017

Landscapes of the London City Region A 25 Year Vision1.

5. The vision (page 6) is a bit anthropocentric, with a focus on communities, a high class economy, and the role of GI in attracting inward investment. The Board would favour a vision which protects nature and landscapes for its own sake, more attuned to the aims of the previous South Oxfordshire GI Strategy (2009) which were: • Preserve and enhance the condition, extent and connectivity of wildlife habitats; • Protect and enhance existing natural and historic assets and provide new green infrastructure assets to meet identified needs; • Reflect and enhance the area’s locally distinctive character, including local landscapes and habitats; • Provide a varied, widely distributed, strategically planned, interconnected and multi-functional green space network; and • Provide a green space network that is accessible to local people, offers recreational opportunities, provides alternative means of transport and promotes healthy lifestyles.

The vision (page 6) could also usefully incorporate the concept of ecosystems services, explaining what nature provides for well-being.

9. We welcome the reference to the Lawton principles on page 1. Suggest illustrating this with a diagram from the Lawton review.

10. On page 2 it would be helpful if the special qualities of the two AONBs were described (they are set out in the AONB Management Plans).

11. On page 13 para 1.2.25 the wording lumps together the AONB and rest of the districts. This fails to give the clarity and distinction to the AONBs, which are nationally protected as among the finest landscapes in the country. For the AONB there is a protective policy framework in NPPF para 115 and 116 and a duty towards the AONB that applies to LPAs under section 85 of the Countryside and Rights of Way Act 2000.

12. The landscape section is just two paragraphs (1.2.25 and 1.2.26) which does not give enough explanation compared with the longer coverage on flooding, biodiversity etc

13. Para 1.4.8 sounds a bit negative “The River Thames forms a physical barrier increasing journey distances and severing communities.” This is one of the key blue corridors and the Thames

1 by AECOM and Ystudio Ltd for the SE Protected Landscapes http://www.surreyhills.org/wpcontent/uploads/2017/04/London-City-Region-Protected-Landscape-Vision-FINAL-5mg.pdf Chilterns Conservation Board Planning Committee Wednesday 22nd November 2017

Path is a National Trail, so suggest making this a bit more positive? In terms of severance, the M40, A34 and railways are also guilty of severance so could also be referred to.

14. Figure 1.9 Indicators of Deprivation the maps are hard to read because they are so small with four maps crammed onto one page, suggest making them one page each like the other maps.

15. Para 2.3.2 on Common Land could add that Commons are one of the special qualities of the Chilterns AONB for which it was designated in 1965.

16. Para 2.4.2 should refer to SACs as our highest level of protected area (sites protected at the European level).

17. Page 35 on watercourses should refer to chalk streams, a globally rare habitat and present in the Chilterns and North Wessex Downs (eg Ewelme Brook in South Oxfordshire see http://www.chilternsaonb.org/about-chilterns/chalk-streams.html which explains that Chalk streams are a characteristic and attractive feature of the Chilterns landscape. They are also a globally rare habitat, confined to north west Europe and to the UK in particular. In fact more than 85% of all the chalk streams in the world, are found in England. Chalk streams are important habitats for wildlife and support a massive range of plants and animals. They are home to some of our most threatened plants and animals, such as the water vole and brown trout. They also have a fascinating history and supported many thriving industries in the past.

18. The key on the maps of ANG provision could be labelled more clearly (Figures 2.5.1 to 2.5.3), rather than “Accessible Natural Greenspace Accessibility- 5km” this could be labelled as “Accessible Natural Greenspace Accessibility within 5km”.

19. GI Design Checklist on pages 47-49 is good but dense to read – improve with illustrations or sketches?

20. The Board supports the identification of Strategic Green and Blue Corridors (Figure 3.1) and supports the high level of coverage of the Chilterns AONB area with the Chilterns Scarp and Woods Green Corridor. Why is a sliver of the Chilterns between the two arrows not covered by the Strategic Green Corridor? It is in the Conservation Target Area. Suggest it would be better to vary the width of the arrows so that this one can be wider and take in the whole Chilterns escarpment and all the CTA here, rather than trying to use two arrows and leaving a gap.

21. The colours, keys and symbols could be improved on Figure 3.1 to avoid confusion between Strategic Green Access Corridors and Strategic Green Access Links. Chilterns Conservation Board Planning Committee Wednesday 22nd November 2017

22. It would be helpful if the Strategic GI area map Figure 3.2 came at the start of the section of these (page 60)

23. In para 3.6.80 more could be added here taken from the South Oxfordshire Landscape Assessment eg about reducing the harm of detractors like golf courses, electricity wires (eg the metal towers at Mapledurham), intensive arable. More bullet points should be added about other areas of the Chilterns further north, eg about the setting of the Chilterns AONB including views from the escarpment and the Ridgeway National Trail (eg from Watlington Hill, Chinnor Hill).

24. In para 3.6.69 there are detractors in the landscape which could be removed/improved around the Ewelme waste facility. Also the effects of outdoor pig farming with pig arks in the landscape.

25. AONB colour (very pale buff) does not show up well on the settlement specific maps eg Figure 3.3.6

26. In the AONB sites that are created as GI should be left unchanged in terms of their appearance, or enhanced for biodiversity. The only thing that may need improving would be accessibility to and through the sites in terms of footpath provision or maintenance. Sites should not be manicured (grass cut and flower beds planted for example) or lit as this would fundamentally change the appearance of the sites and would not be likely to lead to conservation and enhancement of the natural beauty of the AONB.

27. Welcome the inclusion of heritage constraints, could the Chilterns historic landscape characterisation (HLC) work be incorporated too, especially the digital mapping. See:

• the Making of the Chilterns Landscape (Chilterns Historic Landscape Characterisation Project Summary)

• the Chilterns Historic Landscape Characterisation Project report

These documents are available as free downloads from the Chilterns AONB website http://www.chilternsaonb.org/conservation- board/board-publications.html or http://www.chilternsaonb.org/conservation-board/planningdevelopment.html

Ditto the new Oxfordshire County Council mapping work:

• Environmental Sensitivity Study (see https://www.oxfordshire.gov.uk/cms/content/environmental-sensitivity- change)

• and Historic Landscape Characterisation Chilterns Conservation Board Planning Committee Wednesday 22nd November 2017

(https://www.oxfordshire.gov.uk/historiclandscape) East West Networ 1) The Board is grateful for the opportunity to comment on the East 2.8.17 Rail k Rail West Rail Phase 2 Round Two consultation. Western Section 2) Chilterns Conservation Board welcomes the removal of Phase 2 electrification from the project. This would have been a Round 2 significant concern because of the level of harm to the landscape consultation that overhead line equipment can cause, as evidenced by the pack Great Western Mainline electrification in the Chilterns AONB.

3) EWR Phase 2 will potentially affect the Chilterns Area of Outstanding Natural Beauty AONB in the Aylesbury to Princes Risborough section. The AONB boundary runs along the railway line for most of the length between Monks Risborough and Little Kimble, and the areas not in the AONB (Princes Risborough to Monks Risborough, and Little Kimble to Nash Lee) are in the setting of the AONB2. The railway is overlooked from high ground from some key visitor viewpoints within the designated landscape: Whiteleaf Hill, Brush Hill, Grangelands, Beacon Hill, Cymbeline’s Castle and Coombe Hill. These important viewpoints from the chalk escarpment, together with the Ridgeway National Trail, are high sensitivity visual receptors. The panoramic views from the chalk escarpment are one of the special qualities of the Chilterns AONB3.

4) The project involves a platform extension at Princes Risborough. The impacts on the Horsenden Conservation Area should be assessed, noting that in 2016 Wycombe District Council consulted on an extension to the Horsenden Conservation Area4 which would extend it over the parkland of Horsenden Manor and towards Princes Risborough station.

5) As well as extending the platform, opportunities should be taken to invest in facilities at Princes Risborough station to allow it to fulfil its potential as a gateway to the Chilterns AONB (eg cycle hire, electric bike hire, café, visitor information point, improved signage, circular walks and new links between the Ridgeway National Trail path and to other public rights of way). This would encourage more day trips to the AONB on sustainable travel modes (the train) from London and other destinations. The Chilterns Conservation Board supports high quality and enjoyable recreation for all; the AONB Management Plan contains the following policies:

• Policy UE5 Access links between town and country for walkers, cyclists and other recreational users should be strengthened.

2 The setting of the AONB is the area within which development and land management proposals, by virtue of their nature, size, scale, siting, materials or design could be considered to have an impact, either positive or negative, on the natural beauty and special qualities of the Chilterns AONB, see Position Statement: Development Affecting the Setting of the Chilterns AONB. 3 The special qualities are set out in Chilterns AONB Management Plan 2014-2019 http://www.chilternsaonb.org/conservation-board/management-plan.html 4 https://www.wycombe.gov.uk/uploads/public/documents/Planning/Conservation-areas-and-listed-buildings/Draft- Horsenden-conservation-area-appraisal.pdf Chilterns Conservation Board Planning Committee Wednesday 22nd November 2017

• Policy UE9 The quality of welcome given to visitors, including the development of new facilities and services where appropriate, should be enhanced. • Policy UE10 Visits to the AONB should be made using environmentally sensitive modes of transport and new provision should be encouraged.

6) It is unclear in the consultation documents whether the only works proposed in the Aylesbury to Princes Risborough section are to Princes Risborough station. If any new signalling, noise barriers, track widening or telecoms masts are required on the Aylesbury to Princes Risborough section, please ensure that these are placed and spaced so as to minimise visual intrusion to the Chilterns AONB e.g. avoid open landscapes or locations where visible from public rights of way or roads. These structures are best placed in existing cuttings and in urban areas, or where screened by trees, buildings or existing infrastructure.

7) Taking opportunities to remove redundant/ obsolete equipment or structures (e.g. old signals) will help meet the Chilterns AONB Management Plan policies D10 and D11 to enhance the landscape by removing existing detractors in the landscape. Together this landscape-led approach would help address the landscape and visual impacts of the East West Rail proposals in the AONB and the setting of the AONB.

• Policy D10 A reduction in the damaging impacts of utilities and other infrastructure should be sought • Policy D11 Enhancement of the landscape of the AONB should be sought be the removal or mitigation or intrusive development

8) The Chilterns Conservation Board would welcome early participation in the design of any structures in the AONB or its setting, and discussion on alternative designs in order to ensure the best outcomes.

9) The Chilterns Conservation Board recommends that the Specification for the main works contractors should include requirements to minimise harm to the Area of Outstanding Natural Beauty. Including this from the outset will help Network Rail demonstrate compliance with your duty to the AONB under section 85 of the Countryside and Rights of Way Act 2000.

10) Care will be needed where new fencing is proposed, and we welcome that Table 5 describes that “fencing will be appropriate for any given location”. This should include consideration of rural character and the visual impact of fencing in the AONB and its setting. Standard Network Rail green metal palisade fencing would not be a sympathetic boundary treatment, and V mesh fencing is only slightly better. The Chilterns Buildings Design Guide5 explains that wooden picket fences or post and rail fences

5 Chilterns Buildings Design Guide available at http://www.chilternsaonb.org/uploads/files/ConservationBoard/PlanningDevelopment/BuildingsDesignGuide2010.pdf Chilterns Conservation Board Planning Committee Wednesday 22nd November 2017

are likely to be appropriate in the AONB. The Board would be happy to assist with advice on materials, style, colour and finish of any fencing required on the Aylesbury to Princes Risborough section.

11) The Board would welcome environmental mitigation measures e.g. planting/ habitat creation and noise mitigation, but care is needed over the design and siting of noise barriers which often have a negative visual impact and can sever habitats.

12) Lighting at Princes Risborough station- this should be the minimum necessary, avoiding any increase in lighting affecting dark skies in the AONB. The Board supports the proposal for LED downward facing, directional fittings. Avoiding LEDs with white and blue wavelengths of the light spectrum and opting for warmer or neutral spectrum lighting may be better for wildlife eg bats, birds, invertebrates6.

13) The Phasing Plan (Table 6) does not explain the timing for the Aylesbury to Princes Risborough section.

Comments on the Design and Access Statement

14) It is unclear why the Design and Access Statement (DAS) does not cover the land in Wycombe District Council that is affected by the Aylesbury to Princes Risborough section?

15) The DAS should make reference to the Chilterns AONB. Para 4.5 Description of the existing Project Area describes the majority of the route as “in rural, predominantly arable, surroundings”. It would be helpful to acknowledge that part of the scheme runs thorough the national protected Chilterns AONB landscape. Similarly section 4.9.49, which describes the Aylesbury to Princes Risborough section, should specifically mention the Chilterns AONB. Example text that could be added to the DAS to cover this is as follows:

The Chiltern Hills run east-west across the centre of Buckinghamshire and are designated as the Chilterns Area of Outstanding Natural Beauty (AONB). In the Aylesbury to Princes Risborough section, the AONB boundary runs along the railway line for most of the length between Monks Risborough and Little Kimble, and the areas outside the AONB (Princes Risborough to Monks Risborough, and Little Kimble to Nash Lee) fall within the setting of the AONB. As a protected landscape of equal planning status to National Parks, great weight should be given to conserving the landscape and scenic beauty of Areas of Outstanding Natural Beauty (as set out in the Government’s National Planning Policy Framework para 115):

“Great weight should be given to conserving landscape and

Waist-high timber fences such as picket fences or post and rail fences where adjacent to farmland, are in keeping with most village or rural surroundings, can be supplemented by a hedge using locally common native species and are the form of enclosure preferred by the Board (section 3.92) 6 Artificial Lighting and Wildlife, interim guidance for the Bat Conservation Trust http://www.bats.org.uk/pages/bats_and_lighting.html Chilterns Conservation Board Planning Committee Wednesday 22nd November 2017

scenic beauty in National Parks, the Broads and Areas of Outstanding Natural Beauty, which have the highest status of protection in relation to landscape and scenic beauty.”

Network Rail has a legal duty under section 85 of the Countryside and Rights of Way Act 2000:

“Countryside and Rights of Way Act 2000 Section 85. General duty of public bodies etc.

In exercising or performing any functions in relation to, or so as to affect, land in an area of outstanding natural beauty, a relevant authority shall have regard to the purpose of conserving and enhancing the natural beauty of the area of outstanding natural beauty.”

The provision ‘or so as to affect’ means that the duty applies also to the setting of the AONB.

Comments on the Draft Environmental Statement

16) The Draft Environmental Statement Chapter 10: Noise and Vibration should expand Table 10.2 to cover rural locations, and acknowledge quiet rural areas as high sensitivity receptors, especially those in the AONB. A cross reference could be added here to page 6 which sets out NPPF para 123 “identify and protect areas of tranquillity which have remained relatively undisturbed by noise and are prized for their recreational and amenity value for this reason”. The section on noise barriers at paras 10.4.99 and 10.7.12 should add ‘landscape and visual impacts of noise barriers’ to the considerations. Para 10.7.13 recommends noise barriers at the top, or crest of cuttings - this should be amended as this is the worst location in terms of landscape and visual impact. This chapter of the ES should contain maps showing the locations where noise barriers are proposed, and describe the design (including height, materials, and siting of barriers). In rural locations and especially in the AONB or the setting of the AONB, noise barriers should be designed and positioned to minimise landscape and visual harm e.g. of minimum height, located carefully on a cutting/ embankment, smooth not stepped tops on slopes, made of timber or living green barriers (not metal or plastic barriers). They should also be of a suitable colour for each stretch selected through an Environmental Colour Assessment process.

17) The Draft Environmental Statement Chapter 12: Landscape and Visual Impacts seems cursory. It does not appear that route-wide infrastructure like fencing, noise barriers, new signals or new telecoms infrastructure (for which the locations have not been made clear in the Round 2 consultation) have been included for assessment in this ES Chapter 12 Landscape and Visual Impacts document. Page 4 lists the designations of landscape value but fails to include the national designated Chilterns AONB. Section 12.8 on Residual Effects does not include a section on Wycombe Council sub-section. Figure 12.5.2 Natural/Ecological Landscape Designations fails to show the AONB boundary clearly (it is shown as a pale hatch which is practically invisible and Chilterns Conservation Board Planning Committee Wednesday 22nd November 2017

dominated by the Green Belt solid bright green colour). As it stands there is not enough emphasis on this national landscape designation; more weight should be given to the Chilterns AONB. Figure 12.5.5 WDC Viewpoint Plan would benefit from additional viewpoints from

• the Ridgeway National Trail at Culverton Crossroads, Princes Risborough • Horsenden (Conservation Area proposed extension) • Brush Hill nature reserve • Beacon Hill overlooking Little Kimble

18) The Draft Environmental Statement Chapter 16: Summary of Mitigation contains no proposals for landscape mitigation, merely repeating the phrase “Landscape and visual impacts arising from construction activities” or “Landscape and visual impacts arising from the introduction of project infrastructure and services.” The scope of mitigation should include landscape enhancements to offset harm to the AONB and the setting of the AONB on a net gain basis. Applying the mitigation hierarchy (avoid, reduce, mitigate) some proactive landscape mitigation should be designed where residual impacts are felt, creating a net positive for landscape as well as for biodiversity, especially where views from the nationally protected Chilterns AONB are involved. This might be woodland belts to screen the railway, or public rights of way improvements to enhance the visitor experience. For example, expanding facilities at Princes Risborough station could allow it to fulfil its potential as a gateway to the Chilterns AONB. The Ridgeway National Trail7 runs close by and can be joined at Princes Risborough. New facilities at the station might involve cycle hire, electric bike hire, café, visitor information point, improved signage, circular walks and new links between the Ridgeway National Trail path and to other public rights of way.

19) The Draft Environmental Statement Chapter 15: Cumulative Effects should at 15.5.9-15.9.10 consider the cumulative effect on the landscape of the changes along the EWR corridor, bringing together the effects at individual viewpoints. Passengers on the railway are receptors and they will experience the elements of the EWR project in series as they journey progresses, creating a cumulative experience of railway infrastructure. Recreational users looking from viewpoints (especially panoramic viewpoints on the Chilterns chalk escarpment8) may see more than one of the EWR structures. The rail corridor may be picked out in the view by new structures and colours (eg fencing, overbridges etc) creating a cumulative effect. Para 15.6.1 acknowledges that inter-project effects have yet to be assessed, but draws up a narrow scope and date cut-off (August 2017). There are many large projects emerging which should be assessed with EWR for their cumulative effects, including HS2, the growth of Aylesbury into Aylesbury Garden Town, strategic housing growth at Princes Risborough and the Oxford to Cambridge expressway to name

7 For Ridgeway information see http://www.chilternsaonb.org/explore-enjoy/walks-rides/ridgeway.html 8 For instance the railway is overlooked from high ground from some key visitor viewpoints within the designated AONB landscape: Whiteleaf Hill, Brush Hill, Grangelands, Beacon Hill, Cymbeline’s Castle and Coombe Hill Chilterns Conservation Board Planning Committee Wednesday 22nd November 2017

but a few. None of these are fully consented or in approved plans yet; HS2 still has schedule 17 consents process to work through, Wycombe District Council plans to reach Regulation 19 publication stage of its Local Plans in October-November 2017. More flexibility should be applied so that the cumulative effects of the many significant emerging proposals can be assessed together.

20) The Board wishes you well in the preparation of your plans and if we can be of further assistance please let us know.

Masterplan Dacoru The Chilterns Conservation Board wishes to make the following 3.8.17 Guidance m BC response on the Two Waters Masterplan: for Two Waters The draft masterplan fails to mention that the River Bulbourne and Draft River Gade are chalk streams, a globally rare habitat and one the Supplement characteristics features of the Chilterns landscape. 85% of the world’s ary Planning chalk streams are found in England. Chalk streams are home to Document some of our most threatened plants and animals. The impact on the chalk stream of the development proposals in the Two Waters masterplan must be carefully assessed. The Board has particular concerns about site 3 and the lower half of site 4. There appears to be little consideration for the Rivers Gade or Bulbourne. The proposal to build up to buildings of up to 6 storeys on what is currently floodplain meadow should be looked at from an ecological perspective as well flood risk. If you need further information please see the Chilterns Chalk Streams Project http://www.chilternsaonb.org/about-chilterns/chalk-streams.html and contact the Chalk Streams Officer Allen Beechey ([email protected]).

High rise building in the setting of the Chilterns AONB could harm the AONB. The viewpoints on Figure 5 identify two wider viewpoints, both from the town, and should also include views from higher land in the Chilterns AONB, a nationally protected landscape. A Landscape and Visual Impact Assessment should be undertaken, particularly given that the proposals include new buildings 16 storeys high. The Chilterns Conservation Board’s Position Statement on Development Affecting the Setting of the Chilterns AONB explains how development outside the AONB but in its setting can cause harm, and recommends measure to address that, it is available at http://www.chilternsaonb.org/conservation-board/planningdevelopment/position-statements.html Cholsey Cholse 1. The Chilterns Conservation Board is grateful for the opportunity to 3.8.17 pre- y comment on your pre-submission Neighbourhood Plan. submission Parish Congratulations - it is one of the better neighbourhood plans we Neigbourho Council have seen. od Plan 2. In particular the Chilterns Conservation Board supports Objectives EO1, EO2 and Policy CNP E1. 3. It would be useful to add reference to the Chilterns AONB Management Plan and North Wessex Downs AONB Management Plan in the supporting text to Objective EO1 and CNP E1. At footnote 26 please add the Chilterns AONB Management Plan, this is the weblink http://www.chilternsaonb.org/conservation- board/management-plan.html 4. We agree with the observation on page 44 that “The northern part of the new development at Fairmile is prominent in medium distance views from the Chilterns to the west of the River Chilterns Conservation Board Planning Committee Wednesday 22nd November 2017

Thames, particularly roads and footpaths in South Stoke, Hailey and Ipsden.” For this reason we stress the importance of a landscape-led approach to the development of the allocated site H1. 5. It would help to include an indicative masterplan to accompany Policy CNPH1 (more detailed than Map 7) showing the location of the access, developable area, any play areas or community facilities, and the area that should be left for green infrastructure and public open space. This could be based on (and add detail to) the map for Chol2 in the Kirkham work for SODC. 6. The installation of rail electrification gantries on the Great Western Railway has harmed the character and appearance of the AONB in Cholsey parish. Suggest adding reference in the transport issues section to the desirability of retrofitting with improved overhead line equipment and landscape mitigation. 7. The definition of AONB in the glossary would be better as: Areas of Outstanding Natural Beauty (AONBs) are designated by the Government for the purpose of ensuring that the special qualities of the finest landscapes in England and Wales are conserved and enhanced. In policy terms they have the same planning status as National Parks. Section 85 of the Countryside and Rights of Way Act 2000 places a statutory duty on all relevant authorities requiring them to have regard to the statutory purpose of conserving and enhancing the natural beauty of AONBs when coming to decisions or carrying out their activities relating to, or affecting land within these areas. 8. The Board is grateful for the opportunity to make these written comments and wishes Cholsey neighbourhood plan group well in the next stages of work. If we can be of further assistance please contact us. Oxfordshire OCC Q1. How important is having a joined-up infrastructure strategy for 7.9.17 Infrastructur Oxfordshire to you, your group or organisation and why? e Strategy A joined-up infrastructure strategy is important so that the impacts of (OXIS) growth can be assessed holistically and the required improvements Public can be planned, including investment in green infrastructure. The Engagemen cumulative effects of change and development need proper t exercise consideration. This needs to look wider than just Oxfordshire however, as high levels of growth are planned in neighbouring counties and in places further afield which will bring more journeys on rail (eg HS2) and car (A34) through Oxfordshire. The three Areas of Outstanding Natural Beauty in Oxfordshire extend well beyond the county and offer a strategic biodiversity and recreation corridors which are of national importance (eg the Ridgeway National Trail linking Avebury in Wiltshire to Ivinghoe Beacon in Buckinghamshire, and the Thames Path). It is crucial to have a joined-up approach to ensure that development is accompanied by improvements to infrastructure. These must be planned and delivered in a way that enhances and does not harm the natural environment, landscape character and the historic assets of the County.

Q2 Do you have any other comments about the draft infrastructure strategy you wish to make? The Draft OXIS is weak on green infrastructure and planning for a better and healthier environment. County-wide work should be undertaken on Green Infrastructure so that the OXIS becomes also a Green Infrastructure Strategy. This should be informed by the Oxfordshire Wildlife and Landscape Study (OWLS), the Oxfordshire Historic Landscape Characterisation project, and the Environmental Chilterns Conservation Board Planning Committee Wednesday 22nd November 2017

Sensitivity Study. It should build on and extend the geographical coverage of the draft South and Vale GI Strategy (July 2017) which the Chilterns Conservation Board warmly welcomed because of its good level of focus on the AONBs; the proposal to maximise GI opportunities arising from nationally designated landscape areas (AONBs) with the associated management organisations and funding structures; the ambition to create bigger, more joined-up and resilient ecological networks that connect, enlarge and enhance existing habitats that create and support healthy ecosystems; to encourage easy, no/low cost physical exercise, and mental health benefits; to restore degraded landscapes through development; and to identify the Strategic Green Infrastructure Network and areas which should be the focus of investment. The combination of South and Vale as a joint document gave it a welcome landscape-scale, and the chance to appreciate and plan for the two adjoining chalk landscape AONBs (North Wessex Downs and Chilterns) in a connected way. This would be even better at Oxfordshire scale.

Comments on the Stage 1 Report: 1. Page 30 explains that that Stage 1 has included establishing existing infrastructure capacity and key issues – but none of these appear to relate to the state of the natural environment. Suggest addition of coverage from the State of Nature in Oxfordshire 2017 report (http://www.wildoxfordshire.org.uk/wpcontent/uploads/2017/03/State_ of_Nature_Oxfordshire_FINAL_LOWRES_NEW_spreadsv4.pdf)

State of Nature in Oxfordshire 2017 Key Findings: • Despite widespread historic loss of species-rich semi-natural grasslands, Oxfordshire still has some of the rarest and finest grasslands in the country. • Our rivers are much cleaner than they were 30 years ago, and targeted action has helped the recovery of local populations of threatened species, such as water vole and otter. • Long-term declines in farmland and woodland biodiversity continue, with some associated species at serious risk of extinction, such as the turtle dove. However, the area of woodland recorded in the county over the last 30 years has increased. • There is continued fragmentation and loss of connectivity across the county’s landscapes, effecting the future viability of habitats and species. Key Actions: • Urgently create larger and more connected areas of high quality habitats. • Help farmers to find financially viable ways of managing land to provide greater benefits to nature. • Improve practical advice and support for communities and landowners. • Ensure better planning for blue and green infrastructure that benefits nature and people. • Put sustainable development that invests in nature at the heart of local decision-making. • Increase access to green space and volunteering opportunities to keep people in touch with the health and well-being benefits of nature. • Develop more collaborations within our strong and diverse environment sector. Chilterns Conservation Board Planning Committee Wednesday 22nd November 2017

• Continue to improve the methodology for monitoring the state of nature across Oxfordshire.

2. Why is there no mention of the three AONBs in Oxfordshire until nearly the end of the report (page 184) and then only in the green infrastructure section? Surely earlier mention of the AONBs as areas of Oxfordshire nationally designated as some of the country’s finest landscapes, and a key recreational, health and biodiversity resource, should come earlier? AONBs are designated by the Government for the purpose of ensuring that the special qualities of the finest landscapes in England and Wales are conserved and enhanced. In policy terms they have the same planning status as National Parks (NPPF para 115). The Countryside and Rights of Way Act 2000 Section 85 places a statutory duty on local authorities to have regard to the purpose of conserving and enhancing the natural beauty of AONBs when coming to decisions or carrying out their activities relating to, or affecting, land within these areas.

3. The mapping (eg Figures 1, 3, 5 and many more than follow) is very poor on the natural environment. It shows only 'waterbody' or 'woodland' as if these are the only significant habitats. As a result it underplays the significance of the many of the rarest and most important habitats in the County eg chalk grasslands. The maps should show all the priority habitats. The AONBs are only depicted on one map (Figure 62).

4. The report lacks coverage of the capacity of the natural environment. Natural Capital is mentioned only briefly and not explained. The Strategy assumes that the levels of growth proposed for Oxfordshire (39% increase in housing, 25% increase in jobs by 2040) should and will happen. It takes a predict and provide approach to dealing with the infrastructure consequences of this growth. The Chilterns Conservation Board recommends that an infrastructure strategy should not simply follow but lead. There could be instances where it is necessary to limit development, for example where pressures would harm the AONB or ensure that the infrastructure solutions proposed are desirable and sustainable e.g. new boreholes to abstract water from chalk aquifers in the AONB (p153) are likely to be a problem.

5. Page 46 suggest delete Fairmile Hospital from the South Oxfordshire list, this development is completed and no further housing is proposed on the site in the South Oxfordshire Local Plan preferred options.

6. Page 40 section 3.1 should refer to airport growth eg Heathrow Third Runway, doubling of Luton airport passenger numbers and consequential airspace changes which will affect passenger travel through and over Oxfordshire. Similarly HS2 is only mentioned in passing.

7. Page 194 states “Although growth within AONBs is severely restricted, development on the AONB periphery can have an impact on the quality and character of these special areas by disrupting views into and out of the areas. Development on the edges of the AONBs will need to be carefully assessed to ensure that they conserve and enhance the quality and natural character of the area.” Chilterns Conservation Board Planning Committee Wednesday 22nd November 2017

This refers only to visual impacts (impacts on views to and from the AONB), but natural beauty is wider than a purely visual or aesthetic matter. This sentence should read: “Although growth within AONBs is severely restricted, development on the AONB periphery (its setting) can impact on the quality, character and integrity of these special areas by for instance disrupting views into and out of the areas, generating traffic through AONBs, raising recreation pressure at key visitor sites, increasing water abstraction to serve development and reducing air quality and tranquillity. Development on the edges of the AONBs will need to be carefully assessed (individually and cumulatively) to ensure that they conserve and enhance the quality, integrity and natural character of the area ”

We hope these comments are useful. The Chilterns Conservation Board wishes the Growth Board well with the next stages of work and if we are able to assist further please get in touch. Three TRDC Question 1: Vision 7.9.17 Rivers Local The vision uses clear strong words in the first sentence “Three Rivers Plan Issues will be recognised as a highly desirable, prosperous and outward- and Options looking District…” but then weakens to a “we will endeavour to protect and call for the character of the area…”. sites and The Chilterns Conservation Board suggests strengthening the second SA sentence by deleting “endeavour to”, so that it read simply “we will protect the character of the area…”. It is currently quite generic and could be improved by referring to the strengths of the district, its role and location, and about assets like the nationally protected Chilterns AONB landscape.

The vision could incorporate words about sustainability eg “Three Rivers will be recognised as a highly desirable, prosperous, sustainable and outward-looking district”

Question 2: Objectives Yes, the Chilterns Conservation Board supports objectives 8 (historic environment), 9 (climate change), 10 (leisure and recreation), 11 (green infrastructure network) and 12 (rivers). The Chilterns Conservation Board recommends adding an objective on conserving and enhancing the natural beauty of the Chilterns AONB. This is a nationally protected landscape, with equal planning protection to a National Park (see NPPF para 115), and it should have an objective relating to its future. Like all public bodies, Three Rivers District Council is subject to Section 85 of the Countryside and Rights of Way Act 2000 which states under “General duty of public bodies etc” “(1) In exercising or performing any functions in relation to, or so as to affect, land in an area of outstanding natural beauty, a relevant authority shall have regard to the purpose of conserving and enhancing the natural beauty of the area of outstanding natural beauty.”

Question 3: Housing Need The Chilterns Conservation Board recommends the lower end (option 1). This is because the district is constrained by the presence of nationally protected landscape (AONB – albeit a small area of the district) and Green Belt. The raw objectively assessed need (OAN) is a policy-off calculation, which becomes a housing requirement through the local plan preparation process, taking into account policy constraints, consultation and the duty to cooperate. Footnote 9 of Chilterns Conservation Board Planning Committee Wednesday 22nd November 2017

NPPF para 14 applies “Local Plans should meet objectively assessed needs, with sufficient flexibility to adapt to rapid change, unless: • any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole • specific policies in this Framework indicate development should be restricted9 Footnote 9. For example, those policies relating to sites protected under the Birds and Habitats Directives (see paragraph 119) and/or designated as Sites of Special Scientific Interest; land designated as Green Belt, Local Green Space, an Area of Outstanding Natural Beauty, Heritage Coast or within a National Park (or the Broads Authority); designated heritage assets; and locations at risk of flooding or coastal erosion”

The three options seem top down, arbitrary (OAN, OAN minus 20%, OAN plus 20%) and lacking local context or distinctiveness. All three options are a major uplift on the adopted Core Strategy level of growth. Options should be built up from an assessment of capacity, sustainability and landscape. This approach would ensure that the local plan sets an appropriate level of growth that reflects both housing need and the capacity of the district to accommodate that need.

Other options that you think should be considered? Options based on an assessment of the capacity of the District to accommodate new housing without harming assets which indicate that development should be restricted (footnote 9 or NPPF para 14). This assessment should include direct impacts on the Chilterns AONB, development in the setting of the AONB, the impacts on the AONB of increases in traffic, noise, air and light pollution, increased recreation pressure, and cumulative impacts* looking at developments planned in other districts. *The SA is also currently lacking in its coverage of cumulative impacts, which are briefly mentioned once (page 13) but not developed further. The Chilterns Conservation Board held an AONB Planning Forum workshop on cumulative effects in March 2017 and is producing a guide to assist local plan teams in this work.

Question 4: Housing Which option or options do you think are the most appropriate to deliver the housing needed? 1. Concentrate new development within existing urban areas 3. Increase the density of development (taller buildings, smaller houses, smaller gardens) Other options that you think should be considered Prioritising the re-use of previously developed land. Question 5: Affordable Housing • Do you agree with the issues that have been identified regarding affordable housing? (outlined in the Issues & Options and Call for Sites Consultation Document) Broadly agree, but it is not correct to say that “In May 2016, the Government won a legal judgement at the Court of Appeal, Chilterns Conservation Board Planning Committee Wednesday 22nd November 2017

which meant that Local Planning Authorities can no longer require affordable housing to be included within developments of less than 10 units or which have a maximum combined gross floor area of less than 1,000sqm.” That is not the case in designated rural areas (including National Parks and AONBs) where a five unit of more contribution can be implemented. • Are there any other options that you think should be considered? A different threshold could be considered for the AONB part of the district. In nationally designated landscapes including National Parks and Areas of Outstanding Natural Beauty contributions towards affordable housing may be sought from smaller schemes than 10 units. See https://www.gov.uk/government/speeches/small-scale- developers “For designated rural areas under section 157 of the Housing Act 1985, which includes National Parks and Areas of Outstanding Natural Beauty, authorities may choose to implement a lower threshold of 5-units or less, beneath which affordable housing and tariff style contributions should not be sought. This will also apply to all residential annexes and extensions. Within these designated areas, if the 5-unit threshold is implemented then payment of affordable housing and tariff style contributions on developments of between 6 to 10 units should also be sought as a cash payment only and be commuted until after completion of units within the development.” • Which option or options do you think are the most appropriate? An option which maximises the percentage of affordable housing and provides it on-site or as near as possible to where it is needed.

Question 7: Transport The options all seem too similar. Air quality and its impact on biodiversity and human health should be considered in these options. Currently the issues and options transport section is confined to issues of traffic and congestion, which is too narrowly focussed. For impacts on biodiversity, see Plantlife Report We Need to Talk About Nitrogen https://www.plantlife.org.uk/uk/about- us/news/air-pollution-is-having-a-devastating-impact-on-plant- diversity

Question 8: Sustainability and Climate Change These options seem muddled – two options on flooding and then one option on transport and greenhouse gases which is not mutually exclusive and the greenhouse gas option seems strangely placed here. The Local Plan should contain policies on ecological building design and renewable energy. These could complement the policies in the Chilterns AONB Management Plan: Chilterns Conservation Board Planning Committee Wednesday 22nd November 2017

• Policy L13 - The management of the landscape to enable it to adapt to climate change and to help mitigate the causes should be promoted. • Policy D12 - Developments should be sought that represent the highest environmental and design standards whilst complementing the character of the AONB. • Policy D13 - The use of renewable energy (particularly wood fuel, solar, hydropower and ground source heat pumps) should be encouraged in appropriate locations. • Do you have any suggestions as to how the Council can identify new housing and other land use allocations in the most sustainable locations within the District? Consider transport hubs in larger settlements for higher levels of growth. Retain firm controls on isolated or sporadic development including conversions of rural buildings and rural replacement dwellings.

Question 9 Are there any matters you think also need to be considered and why?

The Issues & Options contains no mention of the nationally protected Chilterns AONB. The Council is under a legal duty to have regard to the purpose of conserving and enhancing the natural beauty of the AONB (Section 85 of the Countryside and Rights of Way Act 2000). For the next version of the emerging Local Plan please include a policy on the AONB. We recommend using the model local plan policy prepared in 2016 by the Chilterns AONB Planning Forum, to provide cross-boundary consistency and a positive example of cooperation on a larger-than-local issue. The Model Policy is available via this weblink (full model policy also provided) Draft BCC Do you have any comments about the vision and objectives of the 26.9.17 Buckingham plan? shire Minerals Objective SO5 is not strong enough on the AONB. It should explicitly and Waste conserve and enhance the Chilterns AONB, not just refer to Local Plan landscape character and treating assets in an “appropriate manner” – Preferred the plan should lead by stating how they will be treated. Options The final sentence of SO5 should seek a net gain for landscape and the AONB as well as biodiversity e.g. through the removal of existing detractor features, and sensitive restoration which provides for improved recreation and enjoyment.

Are there any aspects of section 7 of the plan that you particularly support or disagree with?

Policy 23: Chilterns Conservation Board disagrees with just identifying the special qualities of the Chilterns AONB as features for protection. The whole AONB should be accorded equal policy weight, regardless of presence of absence of special qualities on an individual site. The correct wording from national policy is ‘conserve and enhance’, not ‘protect’. The policy fails to address major development in the AONB, which NPPF para 116 explains should be refused except in exceptional circumstances and where it can be Chilterns Conservation Board Planning Committee Wednesday 22nd November 2017

demonstrated they are in the public interest. CCB objects to permitting waste proposals within or adjoin the AONB where criteria are met – the presumption should be no major development in the AONB. Please reword using the AONB model policy: (full text of model policy provided see weblink). Para 7.54 and 7.5 could be improved by replacing this text with the model AONB policy supporting text agreed at the Chilterns AONB Planning Forum in 2016:

Do you have any further comments on the plan? 1) The Key Diagram is misleading – the position of the purple triangle fails to show that the main site for waste management at High Wycombe is in the Chilterns AONB.

2) The Chilterns Conservation Board questions whether enough weight been given to the AONB. NPPW states that “Waste planning authorities should identify, in their Local Plans, sites and/or areas for new or enhanced waste management facilities in appropriate locations”. As a nationally designated landscape why has the AONB not been explicitly avoided?

3) It is not clear that the landscape capacity and visual sensitivity assessment undertaken as part of the Site Assessment Methodology has involved any fieldwork. A desktop assessment based on presence or absence of designations is not enough when making allocations, BCC needs to demonstrate its duty of regard towards conserving and enhancing the natural beauty of the AONB (CRoW Act 2000 sec 85). Assessments from qualified landscape professionals using nationally established methodology (Guidelines for Landscape and Visual Impact Assessment, 3rd edition, Landscape Institute). The setting of AONB also needs careful consideration, please see the Chilterns Conservation Board’s Position Statement of Development Affecting the Setting of the Chilterns AONB.

4) Please be aware of the importance of chalk streams as an internationally rare habitat. The plan fails to mention chalk streams. In Buckinghamshire these include the River Chess, River Misbourne, River Wye, Hughendon Stream and the Hambledon Brook. For instance, the River Chess at Chesham is a chalk stream which runs past an existing waste facility. How has the Site Assessment process factored in impact on AONB and its setting, and impact on chalk streams and chalk aquifers?

5) The proposed waste spatial strategy should include reference to AONB as well as Green Belt: Policy 11. Add AONB as follows: Within rural areas, and where not inappropriate within the green belt and AONB, the development of facilities that incorporate the biological treatment of waste or that are incompatible with urban development will be supported and given priority where (i) associated with existing rural employment uses or farm-based enterprises, and/or (ii) involving the re-use of previously developed land, redundant agricultural and forestry buildings and their curtilages.

Delete AONB as follows: Facilities for the preparation of wastes for re-use and recycling within or adjoining the Chilterns AONB will be supported where appropriate. Chilterns Conservation Board Planning Committee Wednesday 22nd November 2017

Reasons: To comply with i) NPPW locational criteria (appendix B), ii) NPPF para 115 which states that great weight should be given to the AONB, and iii) BCC’s duty towards the AONB under the Countryside and Rights of Way Act 2000 section 85. Biological treatment of waste could constitute major development in the AONB (to which para NPPF 116 applies) and a range of types of harm to the AONB could be involved: landscape and visual impact, noise, traffic generation, risk of nitrogen deposition, biodiversity impacts from attraction of insects, vermin and birds, air pollution and odours, effects on watercourses etc.

6) Policies 2 and 5: Chilterns Conservation Board supports the encouragement of the Chiltern brick industry which is important for providing local materials for repair of historic buildings and construction of sympathetically designed new ones. Existing brickworks sites should be safeguarded so that any that close could be reopened in future. Two of the three brickworks making Chilterns bricks have closed in recent years.

7) Policy 9: Chilterns Conservation Board supports the approach to no oil and gas sites or equipment in the AONB, but the approach to sites under the AONB should be strengthened to also prohibit this, as harm to the chalk aquifer is likely.

8) The Chilterns Conservation Board is concerned that several proposed allocations directly affect the Chilterns AONB, either by being within the AONB or in its setting:

• High Heavens (Great Marlow) - This site is in the AONB - why is this only yellow flagged in the site assessment? More weight should be given to conserving and enhancing the AONB, this is a nationally protected landscape. How will waste development achieve AONB conservation and enhancement? • Wycombe Air Park – in setting of AONB • Aylesbury South East North of A41 (Weston Turville/Aston Clinton) – in setting of AONB, visible from important public views on chalk escarpment, cumulative effect from other developments eg growth of Aylesbury Garden Town, HS2, and East-West Rail. • Triangle Business Park (Stoke Mandeville) - in setting of AONB, visible from important public views on chalk escarpment (Coombe Hill), cumulative effect from other developments eg growth of Aylesbury Garden Town, HS2, and East-West Rail. • Sands Industrial Estate – in setting of AONB • Asheridge Road (Chesham) – in setting of AONB - given this, on what basis can it be given an ‘in principle’ acceptability for waste development (Preferred Options para 5.88)?

9) Local Plan monitoring framework – disagree with trigger point for Policy 23. Rather than a trigger if “more than two” proposals are approved, this should be replaced with “Any”. The AONB is an irreplaceable nationally designated asset. Minerals and waste developments are often major in their scale and impacts, there should not be even one non-policy complaint approval. Chilterns Conservation Board Planning Committee Wednesday 22nd November 2017

Great and WDC The Chilterns Conservation Board has no objection to the proposed 19.10.17 Little Kimble Great and Little Kimble neighbourhood area. It covers the whole neighbourho parish which is the preferred unit for a neighbourhood area in a od plan parished area under 61G(4) of the Town and Country Planning Act Area 1990. designation

AONB Advice to the Parish Council 1. At this initial stage, we would like to offer some standard advice to the neighbourhood plan group about the purposes of AONB designation and the government policies that apply here.

2. We note that over a third of the proposed neighbourhood area (south east of the railway line between Monks Risborough and Little Kimble, then south east of the Aylesbury Road) falls within the Chilterns Area of Outstanding Natural Beauty (AONB), and the area that is not designated AONB forms part of the setting of the Chilterns AONB. The panoramic views from top of the escarpment (especially Beacon Hill and Pulpit Hill) and the views to these dramatic chalk landforms makes this parish particularly special. The area is also rich in history and contains habitats identified as of international value (Special Area of Conservation) and national value (SSSIs and ancient woodland), local wildlife sites and biodiversity opportunity areas (see map attached).

3. As a protected landscape, with equal planning status to National Parks, great weight should be given to conserving landscape and scenic beauty of Areas of Outstanding Natural Beauty (set out in the Government’s National Planning Policy Framework para 115). Paragraphs 116 of the NPPF explains 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. Consideration of such applications should include an assessment of: • the need for the development, including in terms of any national considerations, and the impact of permitting it, or refusing it, upon the local economy; • the cost of, and scope for, developing elsewhere outside the designated area, or meeting the need for it in some other way; and • any detrimental effect on the environment, the landscape and recreational opportunities, and the extent to which that could be moderated.”

4. The Great and Little Kimble Neighbourhood Plan needs to have regard to national policy, including policy on AONBs, and be in general conformity with the strategic policies in Wycombe District Council's development plan, as these form some of the basic conditions against which neighbourhood plans are tested at examination.

5. Great and Little Kimble-cum-Marsh Parish Council, like Wycombe District Council, is a public body subject to the duty in the Countryside and Rights of Way Act 2000 Section 85 that “In exercising or performing any functions in relation to, or so as to affect, land in an area of outstanding natural beauty, a relevant Chilterns Conservation Board Planning Committee Wednesday 22nd November 2017

authority shall have regard to the purpose of conserving and enhancing the natural beauty of the area of outstanding natural beauty”.

6. The Chilterns Conservation Board will wish to stay involved and assist in the future with plan proposals as they develop, to ensure that full and proper account is taken of the need to conserve and enhance the natural beauty of the Chilterns AONB.

7. We have a model AONB policy and some advice on our neighbourhood planning webpage. For more information and advice please contact the Chilterns Conservation Board at [email protected].

8. We wish the Parish Council all the best for the preparation of their Neighbourhood Plan. Ivinghoe AVDC 1. The Chilterns Conservation would welcome more emphasis on 19.10.17 Parish NDP the Chilterns Area of Outstanding Natural Beauty. As it stands Draft pre- the AONB is hardly mentioned, there is little recognition of its submission status or value, and the only policy provision for it is weaker plan than national and local plan policy for the AONB. 2. We would like to offer some advice about the purposes of AONB designation and the government policies that apply here. 3. Well over half of the neighbourhood area falls within the Chilterns Area of Outstanding Natural Beauty (AONB), and the area that is not designated AONB forms part of the setting of the Chilterns AONB. The panoramic views from top of the escarpment (especially the iconic Ivinghoe Beacon) and the views to this dramatic chalk landform makes this a special and remarkable area of which the parish should be justly proud. The area is rich in history, with a hillfort, barrow and ancient earthworks in the hills, and contains habitats identified as of international value (Special Area of Conservation) and national value (SSSIs and ancient woodland), and biodiversity opportunity areas (see map attached). 4. As a protected landscape, with equal planning status to National Parks, great weight should be given to conserving landscape and scenic beauty of Areas of Outstanding Natural Beauty (set out in the Government’s National Planning Policy Framework para 115 ). Paragraphs 116 of the NPPF explains 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. Consideration of such applications should include an assessment of: • the need for the development, including in terms of any national considerations, and the impact of permitting it, or refusing it, upon the local economy; • the cost of, and scope for, developing elsewhere outside the designated area, or meeting the need for it in some other way; and 5. The Ivinghoe Neighbourhood Plan needs to have regard to national policy, including policy on AONBs, and be in general conformity with the strategic policies in AVDC's development plan, as these form some of the basic conditions against which neighbourhood plans are tested at examination. Chilterns Conservation Board Planning Committee Wednesday 22nd November 2017

6. Ivinghoe Parish Council, like AVDC, is a public body subject to the duty in the Countryside and Rights of Way Act 2000 Section 85 that “In exercising or performing any functions in relation to, or so as to affect, land in an area of outstanding natural beauty, a relevant authority shall have regard to the purpose of conserving and enhancing the natural beauty of the area of outstanding natural beauty”.

Detailed comments on the plan 7. In paragraph 2.3 add reference to the AONB as being nationally designated as one of the country’s finest landscapes. 8. The plan should refer to the Chilterns AONB Management Plan 2014-2019: A Framework for Action (Chilterns Conservation Board). Government Planning guidance explains that AONB management plans should be taken into account in neighbourhood plans, see https://www.gov.uk/guidance/natural- environment para 004 Reference ID: 8-004-20140306 9. Suggest referring landscape character assessment: Aylesbury Vale LCA (2008) Jacobs Engineering http://old.buckscc.gov.uk/environment/heritage- ecology/landscape/buckinghamshire-landscape-character- assessment/aylesbury-vale-landscape-character-assessment/ 10. Other documents that may be of assistance for your plan: • the Chilterns Buildings Design Guide • the Buildings Design Guide Supplementary Technical Notes dealing with Flint, Brick and Roofing Materials, • the Environmental Guidelines for the Management of Highways in the Chilterns • the Chilterns Conservation Board’s Position Statement on Development Affecting the Setting of the Chilterns AONB • the Chilterns Conservation Board’s Position Statement on Renewable Energy • the Making of the Chilterns Landscape (Chilterns Historic Landscape Characterisation Project Summary) • the Chilterns Historic Landscape Characterisation Project report All of these documents are available as free downloads from the Chilterns AONB website http://www.chilternsaonb.org/conservation-board/board- publications.html or http://www.chilternsaonb.org/conservation-board/planningdevelopment.html

11. Please refer the Ridgeway National Trail in paras 2.10 and 9.7.3. Ivinghoe Beacon is the end of this ancient route, it is of national importance, see http://www.chilternsaonb.org/explore- enjoy/walks-rides/ridgeway.html 12. Housing Objective refers to the “landscape setting of the Parish”, do you mean the landscape setting of the village? As it stands the objective will apply to the whole parish, including the hamlets and open land in the AONB. The policy itself HSG1 correctly restricts the scope to Ivinghoe village. 13. To show where the policies apply, it would assist if there was a map showing the settlement boundaries of Ivinghoe and Ivinghoe Aston (policy HSG1), and the area elsewhere outside these settlements (policy HSG2). 14. Regarding the text in HSG1 “does not give rise to unacceptable impacts on views into and out of the Green Belt or Area of Chilterns Conservation Board Planning Committee Wednesday 22nd November 2017

Outstanding Nature Beauty (AONB)”. Since the Green Belt is not a landscape designation this would be better phrased as two bullets: • Does not give rise to unacceptable impacts on views into and out of the Area of Outstanding Nature Beauty (AONB) • Meets Green Belt policies in national guidance on appropriate development 15. HSG2 suggest re-phrase this policy, as it stands a housebuilder could make the case that housing in the rural AONB is a business need (i.e. required for their housebuilding business to succeed). Suggest restrict to an essential need for housing a worker for a land-based rural-business eg farming, forestry, possibly rural tourism. The word “resisted” could also be strengthened to “refused”. As it stands this policy is undermining and weakening national policy for Green Belt and AONB (which does not seem the steering group’s intention given the words in 9.4.2 that “The policies seek to preserve the rural open countryside”). 16. As a general point eg HSG2, ENV1, ENV2, ENV3, these policies will be used to determine planning applications, so they should give a clear instruction to the decision-maker and not an indication of the parish council’s view. Look for other ways of expressing eg encouraged or supported could read ‘permitted’, resisted could read ‘refused’. 17. ENV2 should list the designations it applies to. “Currently protected” implies the designations could change in future, better to refer to “designated areas”? 18. The relationship between ENV2 and ENV3 is complicated. ENV2 appears to cover designated areas eg AONB. ENV3 appears to apply to proposals which have passed ENV2, so would also be in designated areas eg AONB, but ENV3 refers to views to and from the Chilterns Hills, implying this policy is about the setting of the AONB not the AONB itself. Please see the Chilterns Conservation Board’s Position Statement on Development Affecting the Setting of the AONB. It explains that developments outside the AONB can affect the AONB in many more ways that visual impacts. ENV3 is currently too narrow in just referring to views. 19. Paragraph 9.5.1 a comment that planting bulbs has a place in the village but would not be right everywhere in the parish eg the species rich chalk grasslands in the AONB. Ivinghoe Parish contains internationally important habitats and is in a Bucks Biodiversity Opportunity Area, suggest you increase the ambition and requirements here in terms of biodiversity enhancements. 20. Figure 17 Environmental constraints map is poor quality and hard to read eg green colour of Parish boundary and SSSIs look too similar. The AONB hatching is obscured by the SAC block colour. 21. Policy TEL1 should refer to nationally protected landscape, as well as rural nature of the neighbourhood. The Board is concerned that “visually sympathetic” could encourage colour or design solutions, but if badly sited and prominent in views masts would still be seriously harmful. The policy should protect from the detrimental effects of poorly sited and poorly designed telecoms infrastructure. Be aware that the latest masts designs may be taller than existing familiar designs, so it is undesirable to give blanket support to the latest designs. The supporting text Chilterns Conservation Board Planning Committee Wednesday 22nd November 2017

indicates that the policy is about broadband, so the policy could be more specifically about broadband infrastructure (e.g. cabinets) and not apply to telecoms (e.g. masts). 22. BUS1 supports business provide it meets other policies in this plan, but the supporting text at para 9.9.1 claims that the policies (why plural when only one BUS policy?) incorporate the key policies of the NPPF paragraph 28, which is does not since there is no reference in the policy to NPPF para 28. Perhaps ‘accords’ is more accurate than ‘incorporate’? 23. We have a model AONB policy and some advice on our neighbourhood planning webpage. For more information and advice please contact the Chilterns Conservation Board at [email protected]. 24. We wish the Parish Council all the best for the finalisation of the Neighbourhood Plan. Chiltern and C&SB 1.11.17 South The Chilterns Conservation Board welcomes the commissioning of Bucks Local detailed work on the landscape capacity of emerging site options for Plan Draft the Chiltern and South Bucks Local Plan. This addresses some of our AONB comments (CCB response to Green Belt Preferred Options, 12th impact December 2016) about the gap in the evidence base regarding studies potential impacts on the AONB. Feedback on draft provided

Consultation DCLG CCB signed a joint response from other AONBs, in summary: 9.11.17 on standardise Question 1: do you agree with the proposed standard approach to d housing assessing local housing need? If not, what alternative approach or methodolog other factors should be considered? y No, we do not agree with the proposed approach for the following reasons: • The proposed multiplier based on the local affordability ratio will not result in lower house prices; • High house prices in the South of England mean that most ‘housing need’ figures will increase, some significantly, because this reflects high demand; • The impact of higher housing numbers in the South of England will be: o Undeliverable housing targets for LPAs which will mean they can’t maintain a five year supply; o As a result, development in locations preferred by developers rather than plan-led sustainable locations; o This general housing pressure in the South of England is reflected in the increased pressure on protected landscapes, particularly AONBs which have seen an 82% increase in housing approvals in the last five years, significantly impacting on their character and natural beauty; • Whilst the consultation refers to the percentage of LPA areas covered by protected landscapes, it does not advise how this should affect housing numbers. This needs to be addressed by clear Government advice, particularly clarifying the application of paragraph 116 of the NPPF, to prevent the current inconsistent approach shown by LPAs and the Planning Inspectorate.

Chilterns Conservation Board Planning Committee Wednesday 22nd November 2017

CCB also submitted a separate response including additional points that:

The methodology fails to acknowledge that high prices may be high simply because an area is beautiful to live in: the logical outcome is that the more beautiful a place is, the more housing its gets to destroy that beauty.

Chilterns Conservation Board: case study of housing numbers We have 10 local planning authorities in the Chilterns Area of Outstanding Natural Beauty:

The consultation sets out what the housing need numbers would be using the proposed national formula. For all but three of our local planning authorities (Chiltern, South Oxfordshire and Dacorum) the number would be higher than numbers in emerging local plans (see table).

Chilterns Conservation Board Planning Committee Wednesday 22nd November 2017

Overall the application of the standard methodology would provide total housing figures of between 2,277 and 2,387 more dwellings per year than current figures for the authorities across the AONB (note in column A that authorities contain land not constrained by the AONB/Green Belt/ SSSI to varying degrees).

The Chilterns Conservation Board calls for an adjustment mechanism and a statement of clear policy protection for nationally designated landscapes including AONBs if the standard methodology is taken forward.

We would welcome further discussions, please use us a case study.

Chiltern and C&SB The Chilterns Conservation Board wishes to make some general 9.11.17 South comments about the brownfield register, as follows: Bucks Brownfield 1. An overview map of all the sites in each district should be provided. Land Ideally this would be an online interactive map. Register Consultation 2. The table of sites should indicate which sites are subject to constraints including the Chilterns AONB, Green Belt, Flood Zone, Special Areas of Conservation, Ancient Woodland, Scheduled Ancient Monuments, SSSI or SSSI buffer etc. Without this information the implication is that these sites are constraint-free, and there may be impacts which constrain the suitability or capacity of a site.

Chilterns Conservation Board Planning Committee Wednesday 22nd November 2017

3. Not all previously developed sites are appropriate for housing, it is important to retain employment and local services eg pubs, garages, especially in rural areas where these may be the last remaining services.

Site specific comments on the suitability of sites:

Sites • CD0209 Newland Park, Gorelands Lane, Chalfont St Giles • CD0444 Land West of Mount Nugent, Chesham • CD0145 Land at Springfield Industrial Estate, Chesham • CD0387 Rear of 64 Whielden Street and 1-3 Alpha Court, Old Amersham are either in or adjacent to the Chilterns AONB. Redevelopment of these sites will require high quality design which reinforces local distinctiveness and respects the landscape, settlement character and special qualities of the AONB. Impacts on the AONB need to be carefully assessed.

CD0209 Newland Park, Gorelands Lane, Chalfont St Giles is not adjoining a settlement and does not appear a suitable location for over 300 homes. It is within the AONB and close to ancient woodland. It is adjacent to the Chilterns Open Air Museum and development, lighting, traffic etc could detract from the experience of visitors to the museum.

CD0444 Land West of Mount Nugent, Chesham is adjacent to the AONB and to ancient woodland. This is likely to limit its suitability.

CD0145 Land at Springfield Industrial Estate, Chesham is adjacent to the AONB and close the River Chess, a chalk stream

CD0387 Rear of 64 Whielden Street and 1-3 Alpha Court, Old Amersham is in the AONB and in a location where it is important to respect the historic morphology of Old Amersham as a valley bottom settlement by keeping development from creeping up the valley slopes.

Chilterns Conservation Board Planning Committee Wednesday 22nd November 2017

APPENDIX 4 Current Development Plan Consultations:

Consultation Consulted Stage Deadline document by for CCB responses Wycombe WDC Reg 19 publication on local plan 27.11.17 Local Plan South SODC Reg 19 publication on local plan 30.11.17 Oxfordshire Local Plan Ivinghoe AVDC Draft neighbourhood plan 6.12.17 Parish NDP Dacorum DBC Issues and Options and draft Sustainability 13.12.17 Local Plan Appraisal Vale of AVDC Reg 19 publication on local plan 14.12.17 Aylesbury Local Plan Goring NP SODC Pre-submission Goring Neighbourhood Plan 13.12.17 North Herts NHDC Examination statement 12.1.17 Local Plan

Chilterns Conservation Board Planning Committee Wednesday 22nd November 2017

Item 10 Planning Applications Update

Author: Mike Stubbs Planning Advisor

Lead Organisations: Chilterns Conservation Board

Resources: Staff time

Summary: Representations have been made regarding a number of planning applications and a number of previous cases have been determined.

Purpose of report: To inform the Committee about, and seek approval of, the responses that have been made under delegated powers in connection with the planning applications as listed and to update the Committee on any outcomes.

Background

1. News on the outcome of previous planning application the Board has made representations on is summarised in Appendix 5. 2. Since the last Planning Committee papers for the 20th July 2017 meeting, the Board has made 23 formal representations on planning applications and one appeal written representations. Of these 7 were objections, 16 were comments and one part comment/ part objection. The formal representations are summarised in Appendix 6. 3. Current live casework is listed in Appendix 7.

Recommendations 1. That the Committee notes and approves the responses made in connection with the applications listed in Appendix 6.

Chilterns Conservation Board Planning Committee Wednesday 22nd November 2017

APPENDIX 5

Update on Status of Planning Applications CCB previously commented upon

Location LPA Development Ref. No. Status CCB response Date CCB

respon ded Land West of NHDC Erection of 660 16/02014/1 Pending CCB Comments 05.03.16 Cockernhoe / dwellings . This land is not AONB, but Land East of shares a similar landscape Copthorne, character and may have Cockernhoe. potential to be incorporated within the nationally protected landscape. CCB dealt with landscape character issues and plan-led system. Valentine WDC Demolition of existing 06/0617/F Refused CCB Comments, revised to 11.11.16 Farm dwellinghouse, UL 31st May objection 25th November Shogmoor stables and former 2017 2016 Lane Skirmett farm buildings and Refused on grounds of being erection of a new unacceptably prominent in the private equestrian AONB. yard alterations

Buildings SODC Use of former feed P13/S0561 Pending CCB Comments. 14.10.16 1,2,4,5,6 and 7 mill as mix of /FUL Lys Mill, Howe B1,B2,B8 and outside Comments dealt with Road near reductions in traffic storage (additional Watlington, movements by rationalising supplementary details floor space in favour of less August 2016 and intensive uses. Noted originally submitted improvements to the access 2013) track to improve the amenity of walkers on the Ridgeway. Former Molins WDC APP/K0425/W/16/3149 Appeal Appeal CCB Objection. Appeal Sports 747 against decision 2.2.17 Ground, Mill non- dismissed The Secretary of State Lane and The determinati 20th July dismissed this appeal and Haven, on of the 2017 supported the Inspector’s Crowbrook outline decision that it was contrary to Road, Monks application green belt policy but that Risborough. for the whilst visible from the AONB demolition at Whiteleaf, development of existing here was acceptable against dwelling, AONB impacts and concluded formation that, ‘the Secretary of State of new considers that the benefits of vehicular the scheme would outweigh access the minor adverse impact on onto the landscape and scenic Crowbrook beauty of the AONB. He thus Road, concludes that, with regard to erection of the AONB, there would be Chilterns Conservation Board Planning Committee Wednesday 22nd November 2017

up to 140 exceptional circumstances in new this case and the appeal dwellings proposal would be in the public interest. However, the Secretary of State shares the Inspector’s view that the harm to the AONB would not be a determinative issue in this case’.

Land at SODC P16/S3142/O Outline Refused CCB Objection 10. 2.17 Kennylands application 20th March Sonning for the 2017 and Reason 2 states that, erection of appealed The application site area September up to 95 borders the Chilterns AONB 2017. dwellings and includes open including farmland which contributes to affordable the character and appearance housing; of the area and new public the enjoyment of a nearby open right of way. The proposed space; development would landscape. diminish the role of the site in protecting and enhancing a distinctive and valued landscape which contributes to the identity of Sonning Common. It would therefore result in the loss of the distinctive landscape boundaries of the existing settlement and harm the valued landscape setting of the AONB and the wider dipslope landscape character of the area Land to rear of SODC P16/S3001/O Erection of Pending – CCB Comments 25.1.17 Cleeve 10 new deferred Cottages dwellings. from CCB has asked that attention Icknield Road (As planning is paid to AONB Management committee Goring amended Plan D1 that ‘The natural 1/2/17 and beauty of the Chilterns AONB amplified should be conserved and by enhanced by encouraging the information highest design standards, received 7, reinforcing local 26 & 31 distinctiveness and respecting October the landscape, settlement 2016 to character and special qualities address of the AONB’. tree and ecology concerns visual impact assessment Chilterns Conservation Board Planning Committee Wednesday 22nd November 2017

The Orchard, CBC CB/17/00501/OUT Outline: Pending CCB Comments 14.7.17 Bedford Road, Demolition Houghton of existing This application appears to Regis, buildings/st raise similar issues to the ructures application at Bury Spinney and Thorn Road Houghton Regis redevelopm for outline approval up to 100 ent of site dwellings (CB/16/02086/OUT). to provide 21 For that application CCB dwellings, commented that the site falls an estate within the Houghton Regis road, Northern Framework Plan landscapin (October 2012) and that this is g and used for development associated management purposes works together with the adopted joint Core Strategy. CCB promoted a consideration of cumulative impacts here, accepting its distance away from the statutory boundary of the protected landscape.

New Barn OCC MW 0094.16 Extraction Pending CCB Objection 9.2.17 Farm, Cholsey of sand and gravel with The adopted Waste and associated Minerals Local Plan Policy processing PE2 establishes that planning plant, permissions will not be given conveyors, for development within land office and outside those identified in that weighbridg plan, unless the apportioned e, parking supply cannot be met from areas. areas identified. Constructio n of new access onto the A4130. Restoration to agriculture. Princes BCC CC/01/17 Creation of Granted CCB Comments 9.2.17 Risborough new 2 6th July School Merton storey 2017 The various extensions sit Road Princes entrance within the framework of the Risborough block with existing school as identified by classrooms option 2 in the pre-application and kitchen scoping of options as set out extension, in the Design and Access central statement. This maintains the atrium and existing relationship to the lift access setting of the AONB by in phase 1; containing the visual impact creation of within the existing built form. 3 storey We accept the point raised in link block. the papers that the existing Chilterns Conservation Board Planning Committee Wednesday 22nd November 2017

sports hall screens much of the site from the AONB. That said, the opportunity to improve materials is beneficial and we would support the architects design and materials (brick). Land west of CBC CB/16/04593 Change of Withdrawn CCB Comments 13.10.16 Chaul End use of the 2.10.17 Road, land from This large greenfield site lies Caddington agricultural within the AONB. The to land for planning application seeks to recreational change the use of agricultural use. land to recreation use, but offers no details on the recreation uses proposed. The application is lacking sufficient information to allow the impacts on the Chilterns AONB to be assessed.

Hazeldene CDC CH/2016/2407/FA Change of Refused CCB Comments 15.2.17 Farm use of farm 19th April Asheridge land for the 2017 and Refused with reason 2 dealing Road stationing appealed. with failure to satisfy AONB Asheridge of 3 no. policy. timber and canvas lodges for tourist accommod ation, formation of track hardstandin g and turning area Land to the SODC P16/S3852/FUL Hybrid Pending CCB Qualified Objection 22.6.17 south of planning Newnham application Objection withdrawn 22.6.17 Manor, for the Crowmarsh erection of Gifford 100 new Planning residential Application dwellings including new access road off the A4074, public open space (full application) and the provision of school land Chilterns Conservation Board Planning Committee Wednesday 22nd November 2017

(outline application)

Land to the SODC P16/S3665/O 80 Refused CCB Objection 9.2.17 west of Old dwellings 10th March Reading Road outline 2017 Refused for reasons including Crowmarsh the AONB location and there Gifford are no exceptional circumstances in the public interest that would justify this major development within the AONB. Land north of PINS APP/J0405/W/16/31 175 Appeal CCB Comments. 25.4.16 Aylesbury 58833 dwellings dismissed Road, with 9th In dismissing this appeal the Wendover vehicular October Planning Inspector concluded accesses 2017 that development fell within onto the setting of the AONB but Aylesbury would result in limited harm to Road and the setting of the AONB and World’s stated ‘it is a pocket of high End Lane. quality land. It also makes a key contribution to the attractive rural setting of Wendover on a gateway approach and forms part of the countryside which provides the setting for the AONB. It has a scenic value well above the ordinary for the reasons given. It is adjoined by and associated with the SSSI which adds value to the local landscape and adds to the sense of rural tranquillity. It is not merely a matter of the site’s well-used internal footpath providing views of the escarpment; rather it is the expansive and scenic nature of those views seen in the context of an open foreground uncluttered by development which gives the views their value and high quality. That is not to impute the characteristics and value of the adjoining AONB to the appeal site but to recognise that the scarp forms part of the backdrop in the smaller scale landscape of which the appeal site is an integral part’. Chilterns Conservation Board Planning Committee Wednesday 22nd November 2017

CABI PINS APP/Q3115/W/16/31 Demolition Appeal CCB Objection 4.7.17 International, 65351 of existing allowed The Planning Inspector in Nosworthy buildings 31st allowing this appeal stated Way, and August that ‘The scenic beauty of the Mongewell, erection of 2017 AONB is determined by its Wallingford, a new special qualities. The site headquarte itself does not exhibit any of rs for CABI; these, is a detractor in its erection of present state and is likely to 91 visually deteriorate further dwellings, over time if the status quo is comprising maintained. Furthermore, the open intense screening along its market and boundaries detaches its affordable internal institutional character housing, from the wider AONB. Any provision of detrimental effects on the open space landscape arise from the and external views and are landscapin primarily linked to the g perception and experience of recreational users of the public rights of way as they travel through the designated countryside. For the reasons given above Iconsider that significant harm would arise in this respect and although it would diminish over time it would still be adverse and thus detrimental.

However the Inspector went on to conclude that exceptional circumstances were demonstrated because, ‘The need for the development and the conclusion that there are presently no alternatives outside the designated area are also matters of substantial importance in the public interest. Improvements to biodiversity and the attractive appearance of the proposed new CABI building would be further positive factors in this case. Overall the benefits would outweigh the limited amount of harm that would be caused to the environment, landscape and recreational opportunities, in my judgement. Chilterns Conservation Board Planning Committee Wednesday 22nd November 2017

Former Molins PINS APP/K0425/W/15/31 Demolition Appeal 2.9.17 Factory Haw 35297 of all dismissed CCB Objection Lane, existing 13th The Secretary of State agreed Saunderton. buildings September with the Planning Inspector in and outline 2017 dismissing this appeal on both planning green belt and AONB grounds permission and concluded that,’ the to construct scheme would not respect its 212 local context and cannot fail dwellings but to seriously harm the (Class C3) sensitive character and with a appearance of the countryside proposed setting and the special footprint of qualities of the Chiltern AONB. 16,208 sq He thus concludes that the metres proposal would conflict with (ground policy WLP Policy L1. floor gross Furthermore it would not external integrate into the natural and area built environment and would including not take the opportunity to garages) improve the character and and total quality of the area (IR259). gross floor Guidance on settlement area of character set out in the CBDG 25,800 sq. would be compromised. metres, Paragraph 116 of the associated Framework does identify that car parking, major development can be pedestrian permitted in exceptional access, circumstances and where it and open can be demonstrated they are space with in the public interest’. access via Haw Lane Land to the SODC P16/S3608/O Outline Refused CCB Comments 25.1.17 east of Benson planning 4th April Lane, application 2017 Reason for refusal includes Crowmarsh for up to the impact upon the setting of Gifford 150 the AONB. dwellings

Chilterns Conservation Board Planning Committee Wednesday 22nd November 2017

APPENDIX 6

New CCB Responses on Planning Applications since Last Planning Committee

Location LPA Ref. No. Development Status Summary of the Board’s Date Response (please contact the

Board for more detailed information if this is required) Land south NHDC 17/00830/1 Mixed use Pending CCB Objection 3.8.17 and north-west application for of Cockernhoe demolition of The Chilterns Conservation and east of existing buildings Board has produced a position Wigmore and construction statement on the setting of the (Stubbocks of up to 1,400 AONB. We are especially Walk), Brick new dwellings interested in the impact upon Kiln Lane, (C3 use) LCA 202 and 212, as this land Cockernhoe together with has potential for incorporation retail, into the Chilterns AONB and educational and CCB proposed a boundary community change in 2013 to include land facilities (A1-A5, in this area of North Herts. D1 and D2 uses) The recommendations set out and associated in the ‘Strategy and Guidelines roads, open for Managing Change’ section space, green of LCA 212 is relevant here in infrastructure that they set out to protect the and ancillary rural character of Lilley infrastructure - Bottom. That rural character outline planning then overlaps with the AONB. application with The area to the east of Luton all matters is a potential candidate for an reserved extension of the AONB based on criteria published by Natural England in March 2011 and relating to landscape quality, scenic quality and relative wildness, relative tranquillity and cultural heritage (Guidance for assessing landscapes for designation as National Park or AONB – 2nd March 2011). In 2004 Beds County Council published ‘The Chilterns AONB Boundary Review: with particular reference to the sector north of Luton’. In September 2010 the North Herts DC cabinet passed a resolution to support consideration of the area as an AONB. The area has a clear affinity with the rest of the Chilterns. It contains clearly recognisable Chilterns features such as chalk streams and associated dry Chilterns Conservation Board Planning Committee Wednesday 22nd November 2017

valleys and small settlements, with isolated farms and dwellings with red brick and flint as dominant building materials. The woodland cover is good, with much of it being Ancient Woodland. This application prejudices any boundary review. We have no timetable from Natural England as to an anticipated reporting and due date for this review. The current application is made in outline and CCB would wish to point out the importance of this future review in the assessment of this current application. The application papers do not deal with this matter. We would ask that attention is given to the potential boundary review in the assessment of cumulative cross boundary long-term impacts on the landscape and associated impacts such as matters of tranquillity and including light pollution, traffic movements and the impact on flora, fauna and geological and physiographical features. Chilterns Conservation Board Planning Committee Wednesday 22nd November 2017

Cotton Spring DBC 4/01733/FUL Planning Granted CCB Comments 11.8.17 Farm, application for 10th Friendless the provision of October This site, albeit contained by Lane, equestrian 2017 its planted boundaries and Flamstead, facilities nearby woodland, has Herts. potential to extend the residential curtilage beyond the previously approved application for residential development (under 4/02353/14/FUL).

It is in our judgment important that any equine use is very low key in nature and fits within the residential curtilage of the previously permitted scheme. This is important here because the landscape around is very rural and exhibits many of the special qualities of the Chilterns AONB. Any equine use would have to be very low key and functionally appear a part of the residential curtilage and not an erosion of the wider rural area. Village Green, PINS HLB_Div8Sec Commons Act Pending CCB Comments 27.7.17 Potten End, Common 16DefraApp 2006 – Section Berkhamsted. Land 16. Application to The Chilterns AONB Decisions deregister an Management Plan 2014 – Application area of Village 2019: A Framework for Action made by Green sets out the special qualities of Hertfordshire the area and presents a vision County of the AONB. Paragraph 10 of Council and the landscape chapter (page Nettleden with 19) reports that ‘over 191 Potten End areas of registered common Parish Council land still provide special landscapes largely untouched by development and modern agriculture. Much of the common land is the Chilterns is in close proximity to towns and villages, providing valued, easily accessible green spaces for local communities.

We do not feel that the extension of the land for parking would conflict with those policies in this case. We would recommend, subject to the powers permitted by the Commons Act 2016, that attention to maintaining a soft Chilterns Conservation Board Planning Committee Wednesday 22nd November 2017

edge to the Common Land is maintained, by virtue of the design of the surfacing and the careful use of open fencing to enclose the parking spaces. These are matters of design detail and not matters of principle. The Wycliffe WDC 17/07241/FUL Demolition of all Pending CCB Comments 20.8.17 Centre existing buildings Horsleys and structures (1) Planning Statement. The Green. and supporting planning statement redevelopment makes reference to a of a supported landscape and visual impact living community assessment (at its 10.39) but (Class C2) we could not find any LVIA on providing 169 the WDC planning portal. units comprising Ordinarily we would comment 115 supported on such a document as this living units, 24 will assist in assessing the care suite units impact on the nearby public and 30 dementia right of way and in overlaying care suites, the relationship between clubhouse existing and replacement incorporating buildings. community (2) Landscape principles. The facilities and principles in the landscape administrative master-plan are to be accommodation supported and they reinforce key issues, such as the reinforcement of the boundary and the retention of apple orchards. The Management Plan also promotes the reintroduction of cherry orchards, if that can be added. We also support the use of soft materials (such as Breedon gravel) and low impact column mounted lighting (3) Design principles. The design approach demonstrates a commitment to the Chilterns Buildings Design Guide. The use of layout and vernacular demonstrates this application. CCB recommends that the materials used are of the highest standard and locally sourced. That would apply to the use of weatherboard cladding and tiles, brickwork and flint work. As before, these matters can be appropriately controlled by Chilterns Conservation Board Planning Committee Wednesday 22nd November 2017

condition but the applicant may want to source some of these details now, which will assist in the determination of the application.

Vehicle CBC CB/17/03719/ Reserved Pending CCB Comments 11.8.17 Storage Area, RM matters Chaul End comprising: On materials we would Road, layout, scale, promote a soft visual Caddington appearance and treatment for the roofing. The Luton CBC landscaping in ‘forticrete’ roof tiles are the reference respect of phase applicant’s submitted 3 (northern preference. CCB suggest parcel) for 201 careful consideration is given dwellings and to a machine made plain clay associated tile and we would refer to development chapter 2 of the approved under supplementary technical note outline planning on roofing. Whilst accepting permission the site is not within the CB/14/02515/OU AONB, but is close and also T. adjoins an area of attractive landscape, the predominance of plain tiling in this part of the wider Chilterns provides a rationale here for some reference to and application of the supplementary note. Burnside WDC 17/07337/FUL Demolition of Pending CCB Comments 29.9.17 Hatches Lane existing Great Kingshill bungalow and The application site sits within Bucks erection of 1 x 4 an existing site and is a part of bed and 1 x 3 the developed part of Great bed detached Kingshill. From a Chilterns dwellings with AONB standpoint the site sits associated at a boundary between open landscaping and land and previously developed access land, albeit all within the defined AONB area. Looking to the future potential for greater infilling and the development of single house plots in this vicinity the Chilterns Conservation Board would recommend that materials follow the guidance in the supplementary technical notes (as above) , especially roofing materials. Chilterns Conservation Board Planning Committee Wednesday 22nd November 2017

Land to the SODC P17/S2324/O Outline Planning Pending CCB Objection 16.8.17 south east of Application with Doveleat all matters From the open access land at Chinnor. reserved (apart the Chinnor Hill Nature from access) for Reserve the site is evident in the erection of the view and displays up to 51 sensitivity. The South dwellings & Oxfordshire Landscape associated Capacity Assessment (2015) infrastructure in which this land is denoted as site Chi 17, clearly identifies a medium to high sensitivity with respect of views from the escarpment. That assessment did not recommend that this site be taken forward, on landscape and visual grounds. The applicant’s landscape consultants downplay or differ in their assessment. On the impact upon views and visual sensitivity they say that the site makes a limited contribution to the visual setting of the AONB and that, in so far as views from Chinnor Hill are concerned, this site is a part of a wider panorama and such views are glimpsed. CCB concurs here with the findings of the South Oxfordshire Landscape Capacity Assessment (2015) that views from Chinnor Hill are matters of ‘Medium / High Visual Sensitivity’.

We disagree with the point raised in appendix 8 of the LVIA that Chi 17 would ‘not greatly add to overall impact of new development on the setting of the AONB’. We disagree with the point raised in conclusion that the site is not as sensitive as set out in the Landscape Capacity assessment.

Looking at the cumulative impacts now materialising CCB would say, on balance, that this application is harmful to the setting of the AONB Chilterns Conservation Board Planning Committee Wednesday 22nd November 2017

Land off Lower SODC P17/S2915/R Approval for Pending CCB Comments 30.8.17 Icknield Way M Reserved Chinnor. Matters (layout, The Chilterns Conservation scale, Board recommends the appearance and submission of additional landscape) details on lighting, including pursuant to suitable explanation and Outline justification of lighting layout, application design and any relevant (P15/S0154/O) technical matters such as for the erection luminous flux / light emitted, of up to 89 30th luminous intensity and beam August angle. 2017dwellings with public open space, landscaping, vehicle access and footpath links at Land off of Lower Icknield Way and consent sought for discharge of conditions 1, 6, 9, 14 and 15. High Heavens BCC SCOP/05/17 Scoping Opinion N/A CCB Comments 16.8.17 Waste for Proposed Management Waste Transfer Chapter 4 deals with Complex at Station landscape protection (with the High Heavens AONB mentioned at 5.12) and Household again commentary on the high Waste Site level duties that apply within Clay Lane an AONB as set out at s85 of Booker Bucks CROW, the Core Strategy and the National Planning Policy Framework 115, is required. CCB would seek a commentary on the consideration of alternative locations for the bio-waste transfer station. These considerations are relevant to a number of cross-cutting issues including hydrology and ground conditions and the engineering assessment of the building. From the papers we note that past historic borehole monitoring has revealed high concentrations of methane (5.101 of chapter 10 to the scoping report) and that this site is built above previous landfill waste and forms unstable made ground. As is reported this results in the need for engineering Chilterns Conservation Board Planning Committee Wednesday 22nd November 2017

designs to address ground instability. An additional complication being the proximity of the aquifer. Professional reassurances are made in the background engineering assessment but it is also stated (at its paragraph 6.0) that the site retains potential to produce significant concentrations of landfill gas.

CCB promotes an assessment of cumulative impacts that deals with a number of background reports set against the environmental sensitivity of the site, its hydrogeology and engineering requirements. These assessments must be set against alternative sites outside the AONB. CCB would ask that this cumulative assessment is undertaken against the key policy background of CS 21, namely the ‘exceptional’ case advanced here in light of AONB status and the principal potential benefit of some landscape restoration and woodland enhancement. The consequence of undertaking such a cumulative assessment in the scoping work for the bio- waste transfer station is that a less sensitive location would be preferable for the longer term planning of this nationally protected landscape. Peppard Road SODC P16/S3630/0 Residential Refused Part comment (existing 31.8.17 and Kiln Road development of 14th AONB boundary) and part and up to 245 Septemb objection (prejudicial to future associated residential er 2017 boundary review). ancillary dwellings and works. All (including up to appeal This application site falls matters 40% affordable lodged. within a location which we reserved with housing), Reason have suggested to Natural the exception structural included England in 2013 for inclusion represents a of the main planning and significant in the AONB in any vehicular landscaping, encroachme forthcoming boundary review. access. Land informal public nt into the Permitting this planning off Peppard open space and open application would have the countryside. Road Emmer children's play effect of prejudicing this AONB Green SODC areas, vehicular boundary review. Once Reference access permitted for housing, there would be no prospect that the Chilterns Conservation Board Planning Committee Wednesday 22nd November 2017

land would become part of the nationally protected landscape. The potential for an AONB boundary review provides the key prism through which these landscape matters must be viewed and assessed. The applicant’s case here is essentially visually based and does not deal with this longer term and strategic or cumulative matter. CCB would respectfully ask the Committee to give weight to this boundary review when deliberating on the application of the planning balance and the duties in paragraph 14 of the NPPF.

CCB has submitted comments here on the basis of the existing statutory boundary of the AONB. We would refine our representation as part comment (existing AONB boundary) and part objection (prejudicial to future boundary review). This recalibration of our conclusions reflects the particular circumstances of this application and we are grateful to put this on record in light of the forthcoming planning committee meeting on 6th September 2017. Land South of SODC P17/S2394/A Proposed Granted CCB Comments 12.9.17 Crowell Road signboards, 6m 27th Chinnor (as flagpoles and Septemb CCB welcomes the general amended by spotlights er 2017 reduction in signage as now plans and proposed. We note that the accompanying conditioned applicant proposes timed Agents email to be illumination for the spotlights illuminated dated 6 between the for 3pm to 7pm. CCB September months of acknowledges that an 2017). November appropriately worded planning to March condition would satisfy the and between the tests of a condition in planning hours of practice guidance. Should the 15:00 and LPA grant consent here we 19:00. would recommend that this stipulation applies to the period November to March and no illumination is permitted outside these months. We assume that the 7pm curfew is to promote the Chilterns Conservation Board Planning Committee Wednesday 22nd November 2017

site during dusk and early evening in the winter months. We would say that a 6pm curfew is more appropriate during winter months.

OS Parcel CDC CH/2017/164 Change of use of Refused CCB Objection 15.9.17 2814 Opposite 8/FA land to a mixed 13th Tiles Farm use as a October Looking at the high level of Asheridge residential and protection afforded to an Road caravan site for further AONB within the Development Asheridge two gypsy action Plan and in the National Bucks families with a reported. Planning Policy Framework at total of up to 3 its paragraph 115 as well as in caravans the Countryside and Rights of (including no Way Act at its section 85, this more than one application cannot be deemed static caravan), to conserve or enhance the laying of landscape. We could not find hardstanding any visual appraisal in the and provision of submitted papers but draw this means of foul conclusion on the basis of drainage landscape character and the (retrospective) immediate topography around the application site.

Development here is harmful to the special qualities of the AONB.

Land off SODC P17/S1867/FUL Full planning Pending CCB Comments Comme Crowell Road, application for nts Chinnor. residential CCB is aware that planning (amende Amended development permission was granted on d plans plans and comprising 58 appeal at the neighbouring submissi on) additional dwellings, new site for 120 dwellings and that 12.9.17 documentation vehicular and the Inspector made the point submitted 30th pedestrian that development here ‘would August 2017. access, internal not materially affect the setting roads and of the AONB’ (paragraph 20 of footpaths, car the appeal decision). That parking, public judgment was based on views open space, out from within the AONB, landscaping, particularly from Chinnor Hill. drainage and CCB would now ask that other associated weight is given to the wider infrastructure views towards the escarpment from within the Vale and that further details are sought in an updated LVIA, together with commentary. Further, CCB would ask that consideration is given to the cumulative impact on these views when the 120 dwelling scheme is factored in and the impacts arising from what is 3 storey development in respect of scale and mass. Chilterns Conservation Board Planning Committee Wednesday 22nd November 2017

The May 2014 landscape capacity assessment for sites on the edge of larger villages did not consider this site and it remains outside the plan- making process and is not allocated within the Neighbourhood Plan, which has passed the examination stage and is prior to referendum. The May 2014 landscape capacity assessment did accept that the land now the subject of the 120 dwelling scheme had potential to affect views out from and to the escarpment. The current application site shares that landscape baseline characteristic. In summary, CCB therefore would ask that the updated LVIA considers the cumulative impacts of both P14/S1586/O and the wider impacts arising from development here and including the 2 and a half to three storey elements, to assess the impact upon the setting of the escarpment when viewed from the north of the current site. Hedges Wood, DBC 4/02186/17/F New cricket Pending CCB Objection. 4.10.17 Bradden Lane, UL pavilion, Gaddesden reinstatement of This application unacceptably Row. pitch and multi- urbanises this site with car use community parking and re-contouring / facility, including engineering of the landscape. café, shop and The frontage of the site would cricket club. be altered in a way that would erode the special qualities of the Chilterns AONB at this point, principally the ‘woodlands, commons, tranquil valleys, the network of ancient routes’ (page 7 of the AONB Management Plan) in a sensitive part of this nationally protected landscape.

The current application does not explain why a café, community hub and farm shop is sought in the proposed building. Chilterns Conservation Board Planning Committee Wednesday 22nd November 2017

Land off PINS APP/Q3115/ Appeal against Pending Written Representations on 1710.17 Wyfold Lane, W/17/318020 the refusal of behalf of the Chilterns Peppard 6 outline Conservation Board Common, application with Oxfordshire - SODC all matters The Chilterns Conservation Planning application reserved, for the Board has concluded that the reference: erection of 7 application is contrary to policy P16/S2887/O Custom Build and demonstrably harmful to dwellings the special qualities of the AONB in this vicinity. The appellant’s second ground of appeal does not withstand the scrutiny of a site visit. (The proposed development would not cause material harm or impact to the character and intrinsic quality of this part of the Chilterns Area of Outstanding Natural Beauty, and that any perceived harm would be more than outweighed by the benefits of the development). The appellant’s submission (in its paragraph 6.25) that tranquilly need not be diminished by development here cannot be correct. Development here would demonstrably erode the tranquillity currently experienced. Crosswater CBC CB/17/04270/ Agricultural Pending CCB Comments 18.10.17 Farm House FULL building Icknield Way We could not find details of Eaton Bray design treatment and Dunstable therefore recommend that attention and weight is given to the Chilterns Buildings Design Guide as the use of materials and design features will be an important consideration in the application of the decision- making duties as set out previously. The Design Guide specifically deals with agricultural and other rural buildings and this could appropriately be a matter for planning condition. Chilterns Conservation Board Planning Committee Wednesday 22nd November 2017

The Firecrest AVDC 17/03798/ALB Installation of 1 x Pending CCB Comments 20.10.17 PH London post mounted Road sign and 3 x sets The existing gable signage Wendover of sign written (facing northwards towards house name Wendover) is illuminated (top letters to the and bottom lit) with the exterior of the hanging sign unilluminated. building. The current application proposes to relocate the hanging sign and add painted signage to the front elevation and south facing wall (facing Great Missenden). CCB understands the need for visibility here but would recommend that the level of illumination is reconsidered and the existing hanging sign, with its historic – traditional form, is retained. For example, the illumination of the front elevation signage would not be needed to attract custom, in view of the other proposed signage. The traditional hanging sign could be replaced with a replica, if weathered (as referred to in the design and access statement) which could include spot lights within its frame.

The Mulberry THDC 17/2169/FUL Erection of Pending CCB Comments 23.10.17 Bush Farm, agricultural Dawes Lane workers dwelling The current application is a Sarratt with associated revised version of application curtilage as refused on 28th June 2017 with a revised siting and design. In all other respects, as far as the AONB is concerned, this application proposes the same mitigation of impact and rationalisation of site uses as previously put forward by the applicant (confirmed in the supporting planning statement at 3.11 and the landscape and visual impact assessment at 14.8). A proliferation of structures is to be resisted and the wider improvement of the land is a matter that was previously considered in the merits of The proposed new location and design details result in a form and design detail that fits Chilterns Conservation Board Planning Committee Wednesday 22nd November 2017

with existing buildings and importantly would not involve any cutting or filling of the landscape, as is to be resisted and as set out in the Chilterns Buildings Design Guide. This location is visually contained and we concur with the conclusions of the LVIA that this would not be visible within the Chess Valley. Little WDC 17/05663/OU Outline Pending CCB Objection 20.10.17 Studdridge T application Farm Ibstone (including details The applicant’s LVIA Road of access) for the commentary makes the point Stokenchurch erection of up to in conclusion (at 1.35) that Bucks 140 dwellings ‘The proposed development (additional (10 of which will forms a natural extension to details- be specialist the existing settlement, whilst October 2017) accommodation respecting and enhancing the for older people) key qualities associated with communal hub this part of the AONB and by for older extension successfully persons' contributes to the accommodation, Conservation Boards four up to 230sqm of ‘Broad Aims’. The retail space (use Conservation Board do not class A1), public accept this point. This open space and application would be positively landscaping. harmful to the special qualities of the AONB by the introduction of built development within open land set within a rural and tranquil context. This land is a constituent part of this sensitive and valued landscape to the south of the settlement and the proposal here would lead to a discordant linear extension at odds with the important rural and nationally protected hinterland around Stokenchurch.

The applicant’s contention in their LVIA commentary that an AONB is not a prohibition on development misses the point here as to the legislative tests in the CROW Act 2000 and the high level policy tests that exist in the Development Plan and in the National Planning Policy Framework at 115 and 116. We would restate the Chilterns Conservation Board Planning Committee Wednesday 22nd November 2017

point that no overriding exceptional circumstances have been presented which demonstrate that the development is in the public interest whereas great weight is given to conserving the landscape and scenic beauty of the area

Land at SODC P17/S3231/O (1) Full planning Pending Part CCB Comment on LVIA 25.10.17 Britwell Road permission for / Part Objection to raised Watlington the demolition of numbers above SODC the existing pig Capacity Study farm and its associated The application proposes a buildings; the greater quantum of housing erection of 183 than contained in the SODC dwellings (Use Landscape Capacity Class C3); the Assessment. We have realignment of interpreted this site to be WAT Britwell Road 12 (with a nominal housing and the creation number of 45 dwellings). The of a new SODC Landscape Capacity vehicular access; Assessment – sites on the the creation of a edge of the larger villages in vehicular access South Oxfordshire Report from the 2015 (Kirkham and Terra industrial estate Firma) deals with this site and road south of makes the point that it is within Cuxham Road; the setting of the AONB and public open development could be visually space; intrusive in views from sustainable Watlington Hill and could urban drainage urbanise the AONB on the far system; side of Britwell Road. The landscaping; and 2015 Report arrives at its other ancillary recommendations on the basis works, including of a reduced development off-site highway area. 183 dwellings, works; and the employment land and a road relocation of a is too much for the site. telecommunicati ons mast and The significant desire to equipment; and integrate this site within the setting of Watlington will be (2) Outline unlikely to be achieved by this permission for up increase in numbers. Further to 650sqm of consideration of the impact of Use Class B1a lighting within the landscape floorspace with would be required, especially access and all towards the site from the other matters elevated viewpoints from reserved. Watlington Hill and in surrounding views within the setting of the AONB. With the increased amount of development now proposed Chilterns Conservation Board Planning Committee Wednesday 22nd November 2017

mitigation planting would not obscure the impact of lighting, particularly when viewed from the escarpment.

We consider that there is the need for an assessment of cumulative impact, including the major proposals at Chalgrove Airfield, and development at Benson.

High Heavens BCC CC/95/17 Infilling of Pending CCB Comments 16.10.17 Waste approximately Management 15,000m3 of We would seek a reassurance Complex at inert material that any inert fill here and the the Lower and drainage concrete slab to cap the filled Dano Area works to create a void would not prejudice the High Heavens concrete slab to longer term use of Household host ancillary ‘exceptionally’ in policy CS 21, Waste waste activities for example if the capping was Complex at the 'Lower a natural substance / material Dano Area' that would allow a more sustainable longer term management for the site. The justification for the capping in concrete appears to be in the interests of further waster transfer activities above this membrane. The exceptional nature of the use must weigh heavily against the point that this land is previously developed land. We would seek reassurance as to the longer term restoration of the site and / or removal of the proposed concrete slab after its operational life, should the waste and minerals authority seeks to approve this application. Policy L6 of the AONB Management Plan states that ‘Degraded aspects of the landscape should be enhanced including the removal or mitigation of intrusive development and features’. Policy D11states that ‘Enhancements of the landscape of the AONB should be sought by the removal or mitigation of intrusive developments’.

CCB would make the point here that these longer term Chilterns Conservation Board Planning Committee Wednesday 22nd November 2017

objective should be given weight when looking to longer term management and restoration of the site. The managements of HGV traffic should be controlled carefully by management agreements to address AONB Management Plan policy D16 which states that ‘The environmental impacts on the Chilterns (including these arising from through traffic) of quarrying and the operation of landfill sites and other waste management facilities within and adjacent to the AONB should be minimised’. OS Parcel WDC 17/07666/OU Outline Pending CCB Comments 30.10.17 8784 & OS T application Parcel 0006 (Including details The proposal is discordant Mill Lane of access) for the with the scattered settlement Monks erection of up to pattern that predominates Risborough 300 dwellings around the scarp hinterland And De with public open and the spring line villages. Graven space, This will be harmful to the Meadows landscaping, views to and from the Askett Village sustainable escarpment and therefore the Lane Askett drainage system special qualities of the AONB Bucks (SuDS) and in this location. vehicular access points from Mill The increase of the application Lane and Askett site area from 8.2 hectares to Village Lane and 17.39 hectares together with demolition of the increase from 170 to 300 existing buildings dwellings requires a recalibration of that balance. In this case CCB argues that the impact upon the view from Whiteleaf would have a detrimental effect on its special character as well as the views back towards the escarpment from footpaths running across the site and to Askett Village. A linear spread of ribbon development would result. Weight must be attributed to the AONB Management Plan and Position Statement on Setting and the Bucks Landscape Character Assessment area 10.6 Risborough Chalk Foothills within Landscape Character Type (LCT) 10 Chalk Foothills. One of the key characteristics of this Chilterns Conservation Board Planning Committee Wednesday 22nd November 2017

landscape character type is as ‘Settlement is prominent within the landscape, nestled at the foot of the escarpment, with a historic character, and modern infilling. Smaller linear settlements occur along roads’. The settlements at the foothills of the scarp are scattered along the spring line, which historically has diffused the development pattern. Westcroft WDC 17/07641/FUL Engineering Pending CCB Comments 30.10.17 Stables Slad operation to Lane Speen create a parking The current application Buckinghamsh area of 44 proposes 44 spaces within a ire spaces making a new area and with total of 82 landscaping and design to spaces create the appearance of a corner copse in the wider setting. The application is supported by a landscape impact assessment and a landscape mitigation in the design treatment proposed. We support the idea proposed and recommend use of native hedgerow planting to create the understory. The materials proposed (tarmac for circulation and gravel for parking) could be softer in appearance if consideration is given to a Breedon type surface. These matters could be acceptably discharged by condition. This would allow some consideration of a softer material and its maintenance regime. Land Off BCC CM/71/17 Proposed Pending CCB Comments 31.10.17 Arrewig Lane extraction of Chartridge approximately (1). The Chilterns Way passes Chesham 24,000 cubic close to the access route and Buckinghamsh metres (40,000 we would propose a ire HP5 2UA tonnes) of clay reasonable buffer distance loam with between the two of between 5 progressive low and 10 metres distance. (2). level restoration An appropriate restoration to agriculture condition should be based on content within the supporting planning statement and submitted plan B25/HGM/03/08. (3). We have seen the holding comments submitted by Natural England, which address landscape Chilterns Conservation Board Planning Committee Wednesday 22nd November 2017

impacts upon the AONB. The planning statement at its annex C deals with landscape assessment matters. Wider views within the landscape are acknowledged at paragraph 4.9 of the planning statement. It would be beneficial to know the wider impact on surrounding views, accepting the nature of proposal and the topography involved.

Chilterns Conservation Board Planning Committee Wednesday 22nd November 2017

APPENDIX 7 Current Live CCB Planning Application Casework

Location LPA Ref number Development Deadline

Vehicle CBC 17/03719/RM Reserved matters 201 22nd storage area dwellings under November Chaul End CB/14/02515/OUT – 2017 Road amended plans Caddington

Kennylands SODC App/Q3115/W/17/3 Appeal 95 dwellings - 24th Sonning 183391 CCB objected and Cllr November Common reversal of officer’s 2017 recommendation

St DBC 4/02341/17/FUL Construction of Multi-Use 1st December Bartholomews Games Area on school 2017 Church of field England School, Common Field, Wigginton, Tring

Rumbolds Pit, SODC MW.0098/17 Change of use for the 7th December Eyres Lane, storage of recycled 2017 Ewelme material on land to the south of the primary working area. In addition to storage of recycled materials it is proposed to store empty waste skips in the ancillary area

Land in Eye SODC P16/S3630/O & Appeal 245 dwellings in 8th December and Dunsden APP/Q3115/W/17/3 setting 2017 185997

Land at Wood SODC P17/S3701/O Outline 23 dwellings 11th Lane December Woodcote 2017