Representor ID:1224473

Chiltern & South Bucks Local Plan Matter 3 Representations submitted on behalf of CALA Homes (Chiltern) Limited and Christopher & David Clementi Representor ID 1224473

ARROW PLANNING LIMITED w: www.arrowplanning.co.uk e: [email protected]

Ref: APL-0131

MATTER 3 1

Representor ID:1224473

Matter 3 – Spatial Strategy Issue 1 – Distribution of Growth

Question 5 How did the Councils decide on the scale and level of growth attributed to the towns and villages in the Plan? For example, why do the allocations in the Plan propose significantly more new dwellings in Beaconsfield than Amersham? What was the process and what alternative strategies were considered?

For the reasons set out in our previous representations, it is contended that the Councils approach to deciding on the scale and level of growth attributed to towns and villages in the Plan is not a sound approach.

The pre-submission Local Plan consultation was accompanied by an undated Settlement Capacity Study. That document appears to have been removed from the Evidence Base and replaced by The Settlement Capacity Study January 2020 (CSBLP58). Despite this being a new document, prepared after the close of the consultation on the Local Plan, it retains many of the flaws of the original, undated, document. These matters are addressed in our original representations at Section 7.0 (p.23-24).

The updated document does now identify the settlements individual settlements have, rather than settlements. However, in some instances, these are incorrectly identified and referenced. Take the example of Little Missenden, which contains Holmer Green. The document states on p.60 and p.61 that Holmer Green “is effectively adjacent to Hazlemere, which is a suburb of High Wycombe (outside of plan area) and is served by the facilities in that settlement”. It therefore recognises that Holmer Green benefits from the facilities in Hazlemere and High Wycombe, yet the listed Services and Facilities on p.60 ignore many of those facilities (e.g. Supermarket in Hazlemere, Hospital & Supermarkets in High Wycombe, schools in both Hazlemere and High Wycombe).

The other key criticism of the Study is the fact that it still fails to consider what capacity each settlement has for growth. The Study just includes an arbitrary statement at the end of each Parish section, proposing a level of growth, that a) bears no relation to the services and facilities in each Parish; and b) is not based on an assessment of the capacity of that area to accommodate growth. This is demonstrated by the consideration of Amersham on p.10. The Study states “These factors suggest that it should accommodate a significant part of the housing demand of the plan area.”, but the scale of growth is not proportionate to other settlements.

This demonstrates that the process of considering the distribution of growth was fundamentally flawed and needs to be revisited. The fact that this Study is dated January 2020, so post-submission of the Local Plan, evidences the fact it is a retrofit piece of work, rather than something prepared to inform the preparation of the Plan. It is asserted that the Plan is therefore not sound, as it is not justified,

MATTER 3

Representor ID:1224473

and that it is necessary to reconsider the approach to the proposed Spatial Strategy and distribution of growth.

Our comments on the SA deal with the lack of consideration of reasonable alternatives and lack of consideration of alternative strategies.

Question 7 Is the spatial strategy and distribution of development consistent with paragraph 103 of the Framework which states that the planning system should actively manage patterns of growth and focus significant development in locations which are, or can be made sustainable?

As set out in our response to Question 5, it is contended that the spatial strategy and distribution of growth methodology is flawed. The result is a spatial strategy which fails to focus significant development in locations which are, or can be made, sustainable.

Whilst a significant allocation is proposed at Beaconsfield, there is scope for further economic and residential development in this highly sustainable location. The Settlement Capacity Study describes Beaconsfield as:

“Beaconsfield is one of the largest towns within the plan area. It is also one of the most accessible locations with its own motorway junction, a good rail service and enjoys a high level of provision of facilities. These factors suggest that it should accommodate a significant part of the housing demand of the plan area.”

In the absence of any evidence which demonstrates why Beaconsfield should not have further growth, it is considered that the town should therefore have a greater allocation of residential and economic development. This would reduce the level of unmet need sent to AVDC and promote sustainable growth in a highly sustainable location in accordance with national planning policy and guidance.

Similarly, Holmer Green should be allocated further development given it’s identified relationship with High Wycombe and Hazlemere1. The relatively small scale allocation in Holmer Green is not proportionate to the high level of sustainability offered by the settlement.

Question 9 Under the heading ‘Strategic Context’, section 3.6 of the Plan refers to strategic plans and projects which may affect the plan area. Amongst others this includes the Oxford-Cambridge Arc, proposals for a third runway at Heathrow and the Western Rail Link. How have these projects been taken into account as part of the Plan’s preparation?

We have set out in our response to Matter 2 Issue 3 that we consider that the Plan has failed to take into account these strategic proposals. The HEDNA in

1 CSBLP58 page 60 and page 61 MATTER 3 3

Representor ID:1224473

particular predates the confirmation of proposals such as Heathrow expansion, despite the third runway scheduled to open in 20282, some 8 years before the expiry of the Plan Period. Proposals such as Heathrow expansion will affect the Districts and lead to likely significant market interest in new economic sites, which in turn will lead to a need for new homes to house the workforce.

Given the certainty of these proposals, and short timescale, it is not appropriate to propose an early review of the new Buckinghamshire-wide Plan, which is likely to be some 5 years away at least. In order to deliver new development to address projects such as Heathrow in 2028, there is a lead in period of a number of years to allow businesses to find sites and develop them, that would be missed without the certainty of a Local Plan adopted in the early 2020s.

Question 10 Is the spatial strategy justified? Does it represent an appropriate strategy when considered against the reasonable alternatives available?

For the reasons set out in our response to Matter 1, Issue 2 (Sustainability Appraisal) and Question 5 above, the spatial strategy has not been tested against all reasonable alternatives. Further growth should have been considered at major settlements such as Beaconsfield, Amersham and Holmer Green, which would reduce the level of unmet need sent to AVDC. This would be a reasonable alternative given the relative level of sustainability of those settlements, yet such an assessment was never undertaken and therefore the spatial strategy cannot currently be considered as justified.

2 https://www.heathrowexpansion.com/news/heathrow-confirms-planning- application-in-2020-alongside-new-delivery-timetable-and-public-consultation/ MATTER 3 4