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Chiltern and South Bucks Local Plan Green Belt Preferred Options Consultation Response

DATE: 11 December 2016

NAME: Mr Richard Biddle ADDRESS: EMAIL:

This response refers solely to the proposal to remove Green Belt status from the area of land referred to as Preferred Site Option 1 to the North East of for the development of 900 homes.

I OBJECT to the proposal to remove the Green Belt status from the area of land referred to as Preferred Site Option 1 to the North East of Chesham for the development of 900 homes for the following reasons.

Japanese Knotweed Infestation

Specifically, it would be unwise to undertake any housing development on land where there is an infestation of Japanese Knotweed. The Green Belt Parcel Reference No 4.020, Area Name Land to the South of Lycrome Road as per the Green Belt Asessment Part Two Draft Report (Ref: http://www.chiltern.gov.uk/CHttpHandler.ashx?id=8730&p=0 Page 39) has an infestation of Japanese Knotweed. See photos.

This has been confirmed as Japanese Knotweed by two qualified sources, an onsite tree surgeon and also by taking a sample to Rowan Garden Centre in Chalfont. The infestation is in the Woodland, clearly visible from the bottom South-West corner of the arable field between Deer Park Walk and Nashleigh House and covers the area the size of a tennis court, a hundred yards South of Nashleigh House.

After Japanese Knotweed eradication, a process that can take up to five years, mortgage and insurance companies avoid having anything to do with neighbouring properties. If housing goes on this field it may be that the properties remain unsold. This fails to alleviate housing shortage yet has an irreversible detrimental effect on the surrounding environment.

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Green Belt Parcel Reference No 4.020, Area Name Land to the South of Lycrome Road sits within the area of land referred to as Preferred Site Option 1 to the North East of Chesham. As a homeowner based 200 yards from this Japanese Knotweed infestation, I object vehemently to any proposal that can trigger further infestation of Japanese Knotweed to surrounding areas.

Asbestos and Infill

From my own experience of living at the Nashleigh Lodge property on Lycrome Road, I am aware that the area (approx 1 acre, possibly more) surrounding the property is built on “landfill”, much of it asbestos. One only needs to dig down 18” locally to hit it. When building a small extension to our house, we had to pay specialists to remove a truck load full of asbestos. It is my understanding that this area was previously the site of a mushroom farm. It is evident that the farm buildings including the asbestos roof were not removed when demolished but used for landfill. It would not be appropriate to build housing on this area of land contained within Green Belt Parcel Reference No 4.020, Area Name Land to the South of Lycrome Road.

Both the items above come under the guidance given in NPPF Paragraph 121 on the suitability of sites for new use.

National Planning Policy Framework (2012) and the Green Belt

The Local Plan should conform to the guidance set out in the National Planning Policy Framework (NPPF). According to the NPPF, Green Belt status should only be removed for “sustainable development” in “exceptional circumstances”. There is a stated preference for the strong protection for the Green Belt in the National Planning Policy Framework (e.g. paragraph 14, footnote 9, paragraph 17 and section 9). For the avoidance of doubt, unmet need does not in itself constitute the “very special circumstances” necessary to permit inappropriate development in the Green Belt.

This is particularly relevant as the exercise to evaluate all possible Brownfield sites locally is not yet completed. The Housing and Economic Land Availability Assessment (HELAA) is still only in draft form. It would be incorrect to say that exceptional circumstances exist whilst the HELAA has yet to be completed.

The HELAA rejects a number of Green Belt plots that share the same characteristics and fewer constraints than Preferred Site Option 1. Reasons given are vague and uninformative. Other sites were also rejected in the HELAA because it was not known at the time if these plots would become available in the future or, in some cases, the identity of the owners of the plots were not known. This demonstrates that the removal of Green Belt status of Lye Green (Preferred Site Option 1) is not an exceptional circumstance and more appropriate sites that require more research should all be looked at first before falling back on this Lye Green site.

Five purpose of the Green Belt

According to the NPPF, the Green Belt serves five purposes:

1. To check the unrestricted sprawl of large built-up areas; 2. To prevent neighbouring towns merging into one another; 3. To assist in safeguarding the countryside from encroachment;

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4. To preserve the setting and special character of historic towns; and 5. To assist in urban regeneration, by encouraging the recycling of derelict and other urban land.

The area of Green Belt surrounding Lye Green performs well in these five purposes:

To check the unrestricted sprawl of large built-up areas

It has successfully prevented any further sprawl of built up areas to the North East of Chesham. The Hill Top & Newtown wards border onto arable fields, the existing Green Belt boundary. Those properties that border onto or sit within this area of Green Belt have had restrictions placed upon them when it comes to extending their properties or building new units as evidenced by the number of correctly rejected planning applications. The key reason cited in these applications is the impact to the openness of the Green Belt. Preferred Site Option 1 as Green Belt prevents unrestricted sprawl of the town of Chesham.

To prevent neighbouring towns merging into one another

Lye Green is a distinct hamlet to the North-East of Chesham with its own history and identity. It has its own Green and a pub as a community hub. Preferred Site Option 1 is the Green Belt that surrounds Lye Green. In the event that Green Belt status is removed, Lye Green will just become part of the Town of Chesham and will threaten the nearby hamlets of , , and Botley with the same fate. , a village one mile to the North will also be under threat of being merged. Preferred Site Option 1 performs well in protecting Lye Green and nearby hamlets from being subsumed by the Town of Chesham, the Green Belt status should not be removed.

To assist in safeguarding the countryside from encroachment

The three fields that make up this rich agricultural land (2 arable, 1 pasture) plus Woodland that make up Preferred Site Option 1 act as buffer towards adjacent areas of land that have AONB status. As per NPPF Paragraph 112: Local planning authorities should take into account the economic and other benefits of the best and most versatile agricultural land. We should not be building on valuable land used for farming.

This area is used regularly by Ramblers, dog-walkers, joggers and Duke of Edinburgh Award candidates. If the Green Belt status is removed there will be nothing between the urban sprawl and AONB. We have already seen the erection of a huge air-hanger-sized barn at the farm next to 23 Ashley Green Road without planning permission and with total disregard to building restrictions within the AONB. Why has this building not been demolished yet? Further breaches of this type are more likely if we remove the Green Belt status from Preferred Site Option 1 and impact the openness of surrounding Green Belt. At the moment, the area of Lye Green performs well as a hamlet that sits within the countryside. Remove the Green Belt status and it will become an expanding urban area that impacts and threatens the environment and openness of the surrounding Green Belt.

One cannot mention the countryside without mentioning the impact on wildlife. Other Consultation responses from my neighbours will go into more detail on this but parts of Preferred Site Option 1 fall within a Biodiversity Opportunity Area and Biological Notification Site. (Ref: Biodiverstiy and Planning in Version 2, March 2014 published by Bucks County Council). Badgers, muntjacs and many other local species of wildlife and birdlife will be irreversibly displaced. These areas, rich with biodiversity, would be severely affected in terms of disturbance, light pollution and

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connectivity if there was development around them. At a national level, the NPPF covers the protections of biodiversity and geodiversity in paragraphs 117-119 and there are no “exceptional circumstances” in this instance to ignore this guidance.

To preserve the setting and special character of historic towns

Chesham as a town has its own history and historical buildings as has Lye Green, a hamlet in its own right, with historical buildings of their own. The buildings of Nashleigh House and Lodge on Lycrome Road date back to the late 1800s. Brockhurst Farm and other local properties date back even earlier. The vehicle traffic from and during the upheaval of developing 900 homes will impact the setting and special character of these dated buildings. Surrounding these unique properties with New Builds will fail to preserve them and most likely lead to them being demolished.

In the Cala Homes Development during the summer of 2014, local residents had to put up with over a month of heavy duty pile-driving for 40-odd dwellings. 100 metres away from my home, the foundations of my 100+ year old house shook with every pile driven. Cala, the developers argued that the piles were required because of the soft inconsistent clay underneath. One could presume that the geology will be the same in Preferred Site Option 1 as it is 100 metres away. There are several older properties nearby. These are peoples’ homes that will not stand up to the ground shock of piles being driven locally for 900 homes.

The current Green Belt status Preferred Site Option 1 performs well in preserving the buildings and unique character of Lye Green.

To assist in urban regeneration, by encouraging the recycling of derelict and other urban land

This Consultation and the preceding Green Belt Assessment should be able to demonstrate this area Preferred Site Option 1 is performing well in the four purposes of the Green Belt above and hence for this fifth purpose is encouraging planners to explore Brownfield as currently underway although incomplete with the HELAA. It is disappointing then that this Green Belt Consultation is required as the Brownfield options have not yet been fully explored. I believe that the current HELAA falls short in its evaluation of local Brownfield sites and is too quick to dismiss their suitability.

The Campaign to Protect Rural England (CPRE) has analysed the Government’s brownfield registers pilot scheme. Employing a variety of conservative methodologies, CPRE now estimates that the available data translates to a minimum of 1.1 million homes on suitable brownfield sites across England. More ambitious methodologies put the figure much higher, towards 1.4 million. This suggests that the Government has previously severely underestimated brownfield capacity. (Ref: http://www.cpre.org.uk/resources/housing-and-planning/housing/item/4416-housing-capacity-on- suitable-brownfield-land)

This being the indisputable case, there is no reason to explore any further the removal of Green Belt Status and planners should be pushing back on this especially as we have demonstrated that Preferred Site Option 1 performs well on the five purposes of the Green Belt and does not represent exceptional circumstances. Sustainable Development

The NPPF states Green Belt status should only be removed for “sustainable development” in “exceptional circumstances”. Above we have demonstrated there are no exceptional circumstances around Preferred Site Option 1.

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I will now demonstrate that development on Preferred Site Option 1 would not be “sustainable development”. Any growth should be proportionate to the relatively limited size of the settlement. Chesham has had to endure more than its fair share of house building in the past without any improvement to its infrastructure. The lack of infrastructure and the unique topography of the Town do not make any further unsustainable development viable.

As I pointed out in my Initial Consultation Response in March 2016 (appended to the end of this response), there does not appear to be any Settlement Infrastructure Capacity Assessment in place. It would be prudent before we decide to build one more house in the Chesham area that we ensure we have the Infrastructure Capacity to cope with it. Chesham has infrastructure failings for its current population that should be addressed first, improved upon and then decisions of development made around infrastructure capacity rather how many houses we can fit on three fields at the top of a hill.

Local Roads

Preferred Site Option 1 is surrounded by three roads: • Nashleigh Hill (leading to the A416 through Chesham) to the East • Lycrome Road to the North • Lye Green Road (leading to White Hill in Chesham) to the South.

At peak times the junction of Nashleigh Hill and Lycrome Road is at capacity. There have been a number of serious accidents at this junction over the last decade (Ref: Jacobs Transport Report in the Evidence Base). Nashleigh Hill is on the main thoroughfare taking you from in the South to Berkhamsted and the A41 in the North. There are no alternative routes. Unless you follow the longer Lycrome Road, Lye Green Road White Hill route into Chesham and the A416. Many take this route when Nashleigh Hill is gridlocked.

Lycrome and Lye Green roads are narrow (in some places the width is not enough for two average- size cars), not designed for heavy traffic use and are already suffering from high volumes of traffic at peak times and other times. The majority of Lycrome Road lacks a safe footpath to walk along and because of areas of impregnable hedges, no escape for pedestrians from oncoming vehicles travelling at speed. This is not a safe road.

It was disappointing therefore that planners chose to ignore the submissions of local residents for the Cala Homes Development on Lycrome Road in 2014 when we warned about additional vehicular activity and parking on roads. We were told that there would be enough parking spaces onsite and no need for vehicles to be parked on the narrow rat run that Lycrome Road has become. Our objections have since proved correct but as this development is now irreversible, the damage done.

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Parking on Lycrome Road has turned this busy rat run into a dangerous single lane road, after Planners had told us that this would not happen despite local resident concerns.

All we ask, as local residents, is that this time planners are prepared to take the concerns of local residents seriously. It is us, after all, that really do know a neighbourhood better than most and have to live with the consequences.

Preferred Site Option 1 sits at the top of a hill. From the centre of the site it would be at least a half hour walk to Chesham Tube Station, longer coming back because of the steep hills. These timings are based on someone of above average fitness. I know as I am one of the few people that walks this route regularly. The vast majority of residents in Lye Green drive their cars into town. They do not cycle, again, because the hills to return are too steep. Buses are too infrequent and with local bus services being cut, not a reliable mode of transport. (Ref: http://lgaconservatives.local.gov.uk/web/guest/media-releases/- /journal_content/56/10180/8040405/NEWS)

Cars are the only option and it would be disingenuous to suggest otherwise about the residents of the 900 homes proposed for Preferred Site Option 1.

There is not the option to widen these roads without removing property. Faced with the physical constraints of these roads, it is clear to see that they could not cope with the additional car journeys generated by 900 homes, not least the heavy-duty construction traffic to build these homes.

Within the town of Chesham itself, the additional traffic will cause further congestion problems as recognised in the Jacobs Transport Report in the Evidence Base. Please also refer to the Highways Agency Report for the development of the site of the Nash Arms at the junction of Nashleigh Hill and Vale Road. Their alarming concerns were for the modest number of five homes.

For these reasons, we object to Preferred Site Option 1 having 900 homes built on it.

Parking in Chesham

Should a resident manage to navigate his/her way by car from the gridlocked area formerly known as Lye Green into Chesham, they then have the task of finding somewhere to park near the Tube station. One has to assume they will need to commute to another town as there are not enough jobs in Chesham for these additional residents from 900 homes. The Tube station car park is at capacity and more frequently finding a space in the town car park is proving challenging.

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They are then forced to take up a free parking space in Chesham residential streets further displacing the problem and creating more congestion as Chesham residents are then forced to drive around looking for a space themselves. One does not need to be a Highways Agency expert to predict this as it is happening now. In this respect, Chesham has a capacity issue that needs to be resolved now otherwise Chesham will become an unattractive place to live as residents leave to find more sustainable places to live. Yes, this response is supposed to be evidence-based but some things cannot be proven unless you have experienced them yourself as a resident. For this reason, I ask the planners that this time they trust the local residents when they say the town of Chesham cannot cope with 900 extra homes at the top of the hill.

Air pollution

Chesham already suffers an air pollution problem. The stretch of A416 from Nashleigh Hill to the “Elgiva” Roundabout is an Air Quality Management Area. The Medical Centre had to be set back from the road due to high levels of Nitrous Oxides. There is no evidence provided in the Local Plan or Evidence Base to suggest building an extra 900 homes in Lye Green will alleviate this problem. Chesham sits in a valley and the pollution collects on the floor of the valley right along the A416. It does not get the opportunity to disperse thus the dangerously high levels of pollution recorded there.

A further 900 homes to the North-East of Chesham will lead to further car journeys into Chesham. More stop-start traffic along the already-congested A416. Stop-Start traffic contributes more pollutants into the air then free-flowing traffic. Pollutants kill. The planning decision to build more homes in Chesham will lead to more deaths in the Town Centre from air pollution. This is indisputable. On the basis of Paragraph 124 of the NPPF, we object to removing the Green Belt Status from Preferred Site Option 1.

Noise pollution

The NPPF is very clear about this in Paragraph 123.

The residents of Lycrome Road had to endure the whole summer of 2014 with the all day sound and foundation juddering of pile-driving. This was to build the modest number of 45 homes in the Cala Homes Development on the old College site. If one extrapolates that number, we can expect a total of 40 months of pile driving from 900 homes plus more for any further building to support the community like the proposed shops and community centres. Almost three and a half years of pile- driving would make the local residents’ lives a misery.

This would specifically fail to abide by the guidance quoted in the NPPF:

● 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 Green Belt, by its very nature is an area of tranquillity. Even when the 900 homes have been built, there will be noise generated from extra traffic, lawn mowers, leaf blowers, music etc. This is indisputable. On the basis of Paragraph 123 of the NPPF, we object to removing the Green Belt Status from Preferred Site Option 1.

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Flooding

It well documented that because the Town of Chesham sits at the bottom of a valley it is more susceptible to flooding. In times of heavy rain, raw sewage is released into the River Chess. This is unacceptable, yet there are no plans from Thames Water to increase the capacity. Tarmac-ing over the Green Belt at the top of the hill allowing more water to flow into Chesham will further exasperate the problem. Building 900 homes on the Green Belt area known as Preferred Site Option 1 is not “sustainable development”, we object on the likelihood of increased flooding.

Schooling

Chesham parents both at Primary and Secondary level face real challenges in placing their children in local school. Many fail and must transport their children to non-local schools adding to the traffic congestion issues. It is incredibly disheartening that a school building on Lycrome Road that could have accommodated all the children from this proposed 900 home estate, allowing them to walk to school, was knocked down to build just 45 homes. The lack of joined-up thinking beggars belief. Who allowed this decision to be made when it was highlighted by local residents at the time that with a growing population we would never need fewer schools, only more? Nevertheless the decision was made and now with this proposal we need to figure out where the children from 900 new homes will be educated. Tapping a few extra classrooms onto Brushwood School will not suffice for the number of children expected in the area. Chesham educational facilities cannot sustain the level of growth in its school-age population expected from building 900 homes in the Green Belt area known as Preferred Site Option 1.

Doctors

It now takes over two weeks to get an appointment with your GP in Chesham; an increase of a week since my previous submission in March 2016. This is indisputable. Current medical facilities in Chesham cannot cope with the influx of 900 homes without degrading its already stretched service levels even further. A new medical centre would be required, yet there is nothing about a new medical centre in the proposal. This appears to have been overlooked and is a major stumbling block in the viability of building 900 homes in the Green Belt area known as Preferred Site Option 1.

Health factors resonate with regard to the proposed Gypsy and Traveller Accommodation proposed for Preferred Site Option 1. This site is not near a hospital, neither does it have good public transport links to any hospital. According to the ORS Buckinghamshire – Gypsy and Traveller Accommodation Needs Assessment (B-GTANA)(Aug 2013), 31% of traveller households interviewed reported that their household contained at least one member with long-term health problems. It is well recognised that more needs to be done to improve the health outcomes of Gypsies and Travellers - Progress report by the ministerial working group on tackling inequalities experienced by Gypsies and Travellers (2012)(Chapter 3). Placing families at this remote site places them at continuing risk of inadequate health provision.

The same concerns apply to the proposed Accommodation for the Elderly. Not near enough to a hospital.

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Infrastructure Spending

Many of the problems above can be alleviated with additional infrastructure spending to address the current shortages listed above but also increase capacity for future growth. Any Capacity Infrastructure Levy or “106” payments may cover one or other of these issues but not all of them. 900 homes is only a modest development so additional payments to cover infrastructure will also be modest unlikely to address the real issue of previous under-spending.

An Infrastructure Delivery Plan should be published before any Local Plan otherwise we will not know what capacity is available to build houses. This will allow everyone to make the most informed decisions.

Publicity regarding this Consultation

This response would not be complete without a complaint about the lacklustre attempts by Council to inform the public regarding the Local Plan. Only those “in the know” had a chance to find out about this. The majority of Chesham residents found out about this via the excellent work of the Brown Not Green Campaign, a group of Chesham residents who have toiled round-the- clock to publicise this Consultation and set up a petition.

It is disappointing that at the time of Council elections we are bombarded with political junk mail, yet the council were not able to send a single mail drop to Chesham residents about a decision that would have far more bearing on their lives then who their next councillor is. Bear in mind that more people have signed the Brown Not Green petition than voted for a single councillor. The answer I got from the Planning Officer I discussed this with at one of the Local Plan exhibitions: “Do you want your council tax to go up?” This was a very weak response and totally insensitive to the blight that this would cause to the lives of Chesham residents. Conclusion

I OBJECT to the proposal to remove the Green Belt status from the area of land referred to as Preferred Site Option 1 to the North East of Chesham for the development of 900 homes. This development is not sustainable and lacks the exceptional circumstances required to remove Green Belt status.

Chiltern District Council needs to properly look at the infrastructure capacity in Chesham before building more homes there to make any development sustainable.

Chiltern District Council also needs to push back on the prospect of building on this Green Belt land as exceptional circumstances do not exist. Nationally we have enough brownfield sites to make up shortfall in housing. These should be exhausted first before the exceptional circumstances can be said to exist for Green Belt development on this land.

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Previous Submission, Consultation March 2016 Included as many of the same arguments still applicable:

We object to the plans to build on Greenbelt put forward in the Local Plan. 1. Most specifically we question the lack of infrastructure in place to sustain a further 1000 houses in the Built Area Extension Option for North-West Chesham. a. Having had a perfectly good school building demolished on Lycrome Road to build new homes we ask where the extra school places will be provided for these extra 1000 homes. Local residents have already found it difficult to get local primary school places for their children. This will put a further strain on the system and gives the impression that there has been little joined up thinking between planning and educational requirements. Please can the council demonstrate where these extra primary and secondary school places will be provided? b. As a local resident, it takes me more than a week to get a doctor’s appointment at the local surgery. An extra 1000 homes will put a further stress on the healthcare system. Will the council be building and staffing further surgeries to accommodate this extra healthcare need? If not, please can the council demonstrate how these extra 1000 homes will be accommodated by the existing overstrained healthcare infrastructure? c. The key roads of the Built Area Extension (Lycrome Road, Lye Green Road & Botley Road) are poorly maintained minor roads that already struggle to accommodate the volume of traffic especially at peak times. They fall in to disrepair frequently with pot-holes a regular occurrence. 1000 more homes will lead to at least 1000 extra cars using these roads daily. Public transport in the form of local buses is minimal and runs at restrictive times. You may be able to get somewhere by bus but the chances are you will not be able to get back when you would like to. This has the effect of forcing people into their cars. This is why we have empty buses. d. The Local Plan fails to demonstrate any kind of Settlement infrastructure Capacity Assessment. Perhaps this should have done before producing the Initial Consultation Document. 2. The use of arable Greenbelt is contentious when there are Brownfield sites readily available. Are these really the “exceptional circumstances” required to build on Greenbelt ahead of Brownfield? Will the council be reverting empty Brownfield sites back to a Greenbelt allocation if they choose not to build on Brownfield? a. It is clear to see that The Green Belt Assessment exercise has been performed on laptop & Google maps with insufficient site visits carried out. No thought has been given to what the Greenbelt land under review is currently being used for. Surely it does not make sense that land currently being used for arable purposes by local farmers should be concreted over. Is the council proposing that the crops being grown and used locally should be trucked in instead by Lorries on our already overcrowded roads? If so, what steps will the council make to better accommodate this heavier traffic on our local roads? b. Can we afford to be so uncaring towards the local wildlife that depends on these fields and undergrowth for habitation and food? We are lucky in the Chilterns that we have been able to live side by side with the local wildlife, indeed this is very much a local feature that draws residents and visitors to the area. Further concrete on Greenbelt areas will make that increasingly unlikely as we become another Metropolitan spread. c. According to the Chesham Society, in excess of 30 Greenbelt locations in the Chesham have been identified that do not serve the five identified Greenbelt Purposes as well the Built Area Extension under review in Chesham. These sites include infills and other areas with little impact on local

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wildlife and the openness of the Greenbelt. These should be built on before we start building on arable farming land. d. A key Chiltern Council objective as quoted on their website (http://www.chiltern.gov.uk/article/2044/Local-Aims--Objectives): i. “is to 'Conserve the environment and promote sustainability', ensuring the continued prosperity of the district, accessibility and appropriate housing provision especially with regard to the redevelopment of previously developed (Brownfield) sites.” ii. The Local Plan fails to make any mention of Brownfield sites or their consideration in the Local Plan Initial Consultation Document. The Local Plan is incomplete as it primarily discusses building on Greenbelt. 3. The Area of Search Strategic Employment Options choice of building a Business Park either side of Ashley Green Road gives little thought to local traffic levels. Already a very busy road at peak times, increasing the amount of traffic into and out of Chesham. Surely a better place to put a local Business Park would be on some of the land next to the A41 or indeed make better use of the space in Chesham Town Centre. Alternatively, the currently disused Brownfield sites along Waterside. A word about Pollution: the Buckinghamshire County Structure Plan (1991 - 2011) (http://www.buckscc.gov.uk/media/136921/structure_plan.pdf) states that "Local Plan policies should take account of the need to separate potentially polluting and other land uses to reduce conflicts and protect the natural environment". Building these 1000 extra homes on Chesham Greenbelt and extending the employment areas along the Greenbelt on either side of Ashley Green Road would add to the air and noise pollution in this part of the County. Chesham Town Council is already failing to achieve compliance with its Environmental Strategy. Air Pollution on Berkhampstead Road and the A416 consistently fails to meet European & DEFRA guidelines. Ref: Chesham Air Quality Management Area (http://aqma.defra.gov.uk/action- plans/CDC%20(Claire)%20AQAP%202010.pdf) and Chiltern’s Local Air & Environment (http://www.chiltern.gov.uk/CHttpHandler.ashx?id=5047&p=0). What steps will Chiltern District take in rectifying this in light of the extra homes being built in the area? A final observation on the format of the Initial Consultation Document: It is written in such a way that a layman without the technical knowledge of planning regulation will easily be overwhelmed by jargon and complexity. The 17 questions are loaded in favour of Greenbelt development and readers are left with a depressing sense of inevitability that whatever points they raise in the consultation response will largely be ignored and or written off as Nimbyism.

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