Vale of Aylesbury Local Plan Draft Consultation

VALE OF AYLESBURY LOCAL PLAN DRAFT CONSULTATION

SUBMISSIONS ON BEHALF OF BERKELEY STRATEGIC LAND LIMITED

SEPTEMBER 2016

Berkeley Strategic

1.0 INTRODUCTION

1.1 This submission is made in response to the Vale of Aylesbury Local Plan - Draft Plan for Summer Consultation Document (August 2016) (“the Draft Plan”). It is made on behalf of Berkeley Strategic Land Limited (“Berkeley”).

1.2 The submission has regard to representations made by Berkeley to the New Wycombe District Council Local Plan June 2016. It is Berkeley’s view that Wycombe District Council (WDC) has greater capacity to accommodate housing in its Green Belt than stated in its New Local Plan (see below). Berkeley is therefore of the opinion that Aylesbury Vale District Council (AVDC) should not be seeking to accommodate nearly a third of Wycombe’s housing need in its plan when this is fundamentally undeliverable (see below).

1.3 Berkeley’s view as to the ability of WDC to meet more of its OAN is based on a Green Belt review, which has been undertaken by Chartered Landscape Architects, fabrik (“the fabrik review”). It shows that there is indeed greater capacity available in Wycombe’s Green Belt. Sites at Flackwell Heath and Bourne End, controlled by Berkeley, are identified below as examples.

2.0 AYLESBURY VALE’S NEW LOCAL PLAN 2033

Background

2.1 The Draft Plan covers the period 2013 – 2033 and sets out a spatial strategy for the delivery of some 33,300 new homes over the Plan period.

2.2 The Draft Plan has been informed by the Buckinghamshire Housing and Economic Development Needs Assessment 2016 (HEDNA). The HEDNA looked at housing need within the Buckinghamshire Housing Market Area (HMA), which includes Aylesbury Vale District Council (AVDC), as well as Chiltern, South Bucks and Wycombe Districts. The housing need in AVDC was found to be 21,300 over the Plan period.

2.3 The Draft Plan is also providing for an estimated unmet housing need of 12,000 from other authorities in the HMA. This includes 5,000 new dwellings (one third) of Wycombe’s housing need of 15,100. The total planned level of housing in Aylesbury Vale District is therefore 33,300 new dwellings.

2.4 Paragraph 3.11 of the Draft Plan states, with reference to the 12,000 dwelling un-met need, that:

“Further capacity work within the housing market area may mean that this will change, so a definitive housing number cannot yet be established.”

2.5 Berkeley supports the need for additional housing capacity work. As set out below, it has detailed evidence to show that WDC has greater capacity within its Green Belt than that identified within its emerging New Local Plan.

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The Spatial Strategy for Growth.

2.6 The Buckinghamshire HEDNA identifies a housing need in AVDC of some 21,300 homes over the Plan period. The Draft Plan seeks to identify enough land to meet this need plus an additional 5,000 homes to meet Wycombe’s unmet need and a proportion of the unmet need from Chiltern District and South Bucks District Council. This has resulted in an AVDC “Spatial Strategy for Growth” (Policy S2) that seeks to deliver 33,300 dwellings over the plan period (2013 – 2033) or 1665 dwellings per annum (dpa).

2.7 AVDC’s most recent 5-year housing land supply position statement (January 2016) shows that between 2001 and 2015 an average of 817 dpa were completed across the district. This means the required rate of delivery is more than double the rate achieved in recent past. Moreover, that statement identifies that there is already a shortfall of 921 completions for the first two years of the Plan. In addition, the housing trajectory only shows housing delivery for AVDC (21,300). Having regard to these issues it is assumed that the additional unmet need of 12,000 will need to be back-loaded with more completions towards the end of the plan period, which must raise concerns over delivery.

2.8 Table 1 - Spatial Strategy for Growth in Aylesbury Vale, which can be found at page 32 in the Draft Plan, shows that even after considering potential sites through its Housing Land Availability Assessment, AVDC is short of suitable sites to accommodate 3,268 dwellings of the 33,300 dwelling target. Moreover, a site still needs to be identified for the 4,500 homes in the new settlement. This raises serious question marks as to the capacity of the district to accommodate the additional homes.

2.9 AVDC states that it is intending to submit its Plan to the Secretary of State in March 2017; to hold the Examination in Public during spring 2017; and to adopt the Plan in the summer of 2017. Having regard to the scale of development proposed and the ‘cross-border’ issues, which are bound to generate a high level of comment and objection, and which, consequently, will require careful and detailed examination, this timetable is optimistic at best. In addition, the Wycombe Local Plan will still be at examination during the summer of 2017. Due to the interlinked nature of the two plans, this may delay the adoption of the Plan.

2.10 Based on the example of Oxfordshire, where the four district councils are being asked to accommodate Oxford City’s unmet need, but where overall the housing numbers are significantly lower than the figures being proposed in Buckinghamshire, it is likely to be two years at least before AVDC Plan is adopted. This can only but give rise to a further cause for concern in terms of the delivery of housing in Wycombe District and across the HMA.

2.11 Berkeley notes that the Draft Plan includes a proposal for a new settlement of some 6,000 new homes, 4,500 of which are to be provided in the plan period. Two possible locations have been highlighted: Haddenham and Winslow. If AVDC has yet to decide on a preferred location for the new settlement, it is again difficult to see how it will have an adopted Plan in place by next year, and how the new settlement can deliver 4,500 homes in the Plan period. By the time the Plan is adopted, planning is secured, the land assembled and

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enabling infrastructure delivered, it is unlikely that the new settlement will deliver any housing until the second half of the Plan period meaning that 4,500 homes would need to be delivered in 10 years, not in a 20 year plan period. This is considered to be unachievable.

2.12 AVDC is also planning to build over 8,000 dwellings at Aylesbury (this is in addition to the existing 5,419 dwellings in the pipe-line from existing allocated sites and other developable sites) and over 4,000 on sites adjacent to Milton Keynes which will require joint working with Milton Keynes Council. The Milton Keynes plan is still at an early stage meaning there is uncertainty about the role of growth on the edge of Milton Keynes as well as unresolved infrastructure issues etc. Moreover, it has taken many years to deliver the existing strategic allocations at Aylesbury and there is no reason to expect that further allocations will come forward any more quickly.

2.13 The Draft Plan does not allocate specific sites in Aylesbury (potential sites are identified) but states at paragraph 4.12 that, where possible, development will be located at suitable previously developed sites in the existing Aylesbury urban area to regenerate the town. The remainder will be linked into sustainable urban extensions on greenfield sites around the town.

2.14 The lead-in times and dwelling completion rates on brownfield sites and regeneration schemes and on large strategic sites tend to be longer than on smaller green field sites. This is because brown field sites frequently have site clearance/contamination issues that slow up development and large strategic green field sites often have land assembly issues, complex section 106 agreements that take longer to negotiate and complex infrastructure requirements that need to be in place before new homes are delivered.

2.15 Seeking to accommodate some 8,000 new homes on large strategic sites on the edge of Aylesbury and on brown field sites within the town, in addition to existing committed sites for 5,419 dwellings, also raises a market saturation issue and is likely to result in developers progressing more slowly than would be the case if AVDC had chosen to adopt a more dispersed strategy with a larger number of smaller sites spread around the district’s larger settlements.

2.16 These factors bear significantly on the ability of the Draft Plan to deliver the number of homes anticipated in the plan period. More importantly, they call in to question the very soundness of the Plan as drafted. There are similar issues with development on sites adjacent to Milton Keynes and as explained above, significant delivery issues with the new settlement.

2.17 In addition to these spatial planning issues, the timely delivery of wider infrastructure projects will be key to AVDC meeting its ambitious housing targets. Paragraph 3.44 of the Draft Plan highlights East–West Rail and the A421 expressway as two such key infrastructure projects.

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announced a preferred route for the eastern section. As such, there are clear timing issues with the full east to west delivery of this key piece of infrastructure, which is inextricably linked to the ambitious housing growth proposed by AVDC.

2.19 In October 2015, the Government announced a study worth £512,000 to explore options into the potential for creating a dedicated road link between Oxford, Milton Keynes and Cambridge. In terms of an A421 expressway to link Oxford and Cambridge, it would seem that the Government is at the early ‘exploratory’ stages of its investment questioning the ability for the route to be delivered within the plan period.

2.20 There are also concerns over sewer capacity. In responding to the AVDC Local Plan ‘Issues and Options’ consultation, Thames Water stated that with exception of Aylesbury the area is served by multiple, distinct, relatively small sewerage treatment works and that early consultation would be required to determine whether the sites proposed for allocation will require the provision of new and/or upgraded sewage infrastructure.

2.21 These wider infrastructure issues also bear on the ability of the AVDC Plan to deliver the quantum of new homes proposed and to do so in a timely manner. Again this goes to the soundness of the Draft Plan as proposed.

2.22 The above demonstrates how the Draft Plan, as proposed, will not deliver the level of housing needed due to a lack of suitable and deliverable sites in the district, the required rate of delivery being unachievable and made worse by back-loading of housing delivery in the latter part of the plan period and long lead-in times for delivery of required infrastructure. This in turn means that the housing need for the HMA will not be met and that the Draft Plan will likely be found unsound. There is also a risk that the strategy will not deliver a rolling 5- year housing land supply leading to the risk of planning by appeal across the HMA.

2.23 On the basis that the working assumption is that the Draft Plan will be delivering approximately one third of WDC’s objectively assessed need (OAN), consideration must also be given to the robustness/deliverability of the WDC’s Local Plan. This we do below.

New Wycombe District Local Plan

2.24 The above analysis shows that there is a very strong likelihood that AVDC will be unable to deliver around one third of WDC’s OAN in the period to 2033. This in turn calls in to question the soundness of WDC’s spatial strategy as set out in the New Wycombe District Local Plan (“Emerging Plan”).

2.25 The solution is for AVDC, through the ‘Duty to Co-operate’ to request that WDC looks again at the options for meeting its own OAN on land within its own boundaries, including land in the Green Belt. Such an approach would be consistent with the Emerging Plan’s vision, which is:

“Wycombe District: economically strong and the place to live work and visit.” (our emphasis)

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2.26 Policy CP2 – Spatial Strategy of the Emerging Plan states that:

“The Council will, through the allocations and policies in the Plan:

…..

b) Protect the Areas of Outstanding Natural Beauty and Green Belt by only allocating sites which perform weak Green Belt functions and that have limited visual impact on the Area of Outstanding Natural Beauty….” (our emphasis)

2.27 It then states at paragraph 4.28 in the Emerging Plan that WDC has “thoroughly reviewed the scope for meeting its housing needs within the district” and that that review has included “reviewing the scope for removing areas of land from the Green Belt where it would not be significantly harmful to the purposes of the Green Belt.”

2.28 Berkeley would question the thoroughness of WDC’s review of sites in the Green Belt. Berkeley’s considered view is that there are additional sites in the Green Belt that have “weak Green Belt functions” and which should be allocated for housing development thereby reducing the reliance on AVDC to meet Wycombe District’s housing need and improving the chances that both plans will be found to be ‘sound’. Berkeley’s case is set out in full in its reps to the Emerging Plan which can be found at Annex 1 of this submission.

Berkeley’s Green Belt Study

2.29 Berkeley has commissioned fabrik Chartered Landscape Architects to carry out a more detailed review of the Buckinghamshire and Wycombe Green Belt Studies which act as background evidence for the Emerging Plan. The fabrik review demonstrates that there are additional sites within the Green Belt that could be brought forward for development to meet more fully the Council’s OAN. It also demonstrates that there are inconsistencies in the approach taken in the Buckinghamshire Green Belt Assessment (BGBA). Moreover, there are a number of additional sub-areas within the General Areas that warrant further consideration but which have not been included in the Assessment.

2.30 In terms of the WDC Draft Green Belt Part 2 Assessment, again, there is an inconsistent approach to the assessment of the individual sites. The identification of sites proposed for Green Belt release is therefore challenged in the fabrik review. There are a number of similarities to be drawn between the proposed Green Belt releases in Wycombe District and the Berkeley sites at Bourne End and Flackwell Heath. The objective landscape analysis of the two Berkeley sites at Flackwell Heath and Bourne End in the fabrik review concludes that the Berkeley sites could come forward and deliver development in a manner which maintains the relevant 3 purposes of the Green Belt in a consistent way to the other sites proposed by WDC. The fabrik review can be found at Annex 2.

2.31 It is clear from the fabrik review that using WDC’s methodology for assessing sites within the Green Belt there is a greater capacity for further development

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than is acknowledged in the Emerging Plan. This means that the level of unmet housing need that AVDC is expected to accommodate is too high. As explained above, it is unlikely the AVDC will be able to provide for its own housing need, let alone the unmet needs of WDC and Chiltern and South Bucks District Councils. It follows therefore that WDC should use the extra capacity to help in meeting its own housing need.

2.32 To assist AVDC, below are three examples of sites within Wycombe District that WDC could soundly allocate in its Emerging Plan to help meet its own OAN and reduce the burden on AVDC.

3.0 HEATH END FARM, FLACKWELL HEATH

3.1 Flackwell Heath is designated as a Tier 3 “Higher Order Service Village” within the Emerging Plan’s settlement hierarchy. This means it has a number of key services and facilities and is considered a sustainable location for development. Policy CP3 – Settlement Hierarchy of the Emerging Plan states that development will be directed towards Tier 3 and 4 villages through limited land removed from the Green Belt as identified in the Emerging Plan.

3.2 Policy CP4 – Delivering Homes in the Plan states that WDC is seeking to deliver 1,100 homes across the rural areas with a focus on the larger and medium sized villages.

3.3 Heath End Farm is a 5.2ha site on the edge of Flackwell Heath and can be seen outlined in red on the plan at Annex 3. Berkeley has control of the site and estimates that it would deliver circa 100 new homes.

3.4 The site is bounded on three sides by existing development and by Oak Wood Copse. There is residential development to the east and south; Amersham & Wycombe College to the west; and the Copse to the north-east. As such, the site’s development would not extend the built up area of Flackwell Heath into open countryside and would represent a sustainable, policy compliant (CP2, CP3 and CP4 from the Emerging Plan above) urban extension.

3.5 The site was considered in WDC’s Housing and Economic Land Availability Assessment November 2015 (HELAA) under site reference SWC0070. However, it was discounted due to its Green Belt location.

3.6 The fabrik review concludes that based on the inconsistencies of the approach to the WDC Green Belt Assessment, Land at Heath End Road should be considered further for Green Belt release (see section 3 of the fabrik review).

3.7 As part of the Landscape Analysis, the fabrik review explains that the site lies to the south of a local ridgeline and on south facing slopes, consistent with the existing developed edge of Flackwell Heath both to the east and west of the site. The site is currently used as paddocks and therefore has a typical urban fringe character.

3.8 The site lies between the existing developed edges associated with Flackwell Heath. Amersham College is identified as a Major Developed site in the

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Green Belt. This site, together with its associated grounds (which include floodlighting) and neighbouring uses form the western edge of Flackwell Heath. Amersham College is clearly visible passing Spring Lane on Heath End Road, especially travelling west. The site includes Heath End Farm and associated buildings.

3.9 The southern edge of the site is influenced by the adjacent residential uses to the south of Heath End Road. There are a series of defensible boundaries present, the ridgeline and the M40 to the north; the woodland to the east; Heath End Road to the south; and Spring Lane to the west. The ribbon of residential development to the south of the site influences the southern edge of the site. The presence of Heath End Farm is apparent when travelling south along Spring Lane.

3.10 The northern edge of Flackwell Heath extends up to the M40 road corridor and is separated from High Wycombe through intervening woodland. Development on this edge comprises of 2 and 3 storey buildings.

3.11 The western edge of Flackwell Heath is defined by the speed restriction sign and traffic island. The road at this point is flanked by trees creating a green corridor. Dwellings become apparent on approaching Spring Lane and once at Spring Lane there is a sense of arriving on the fringes of Flackwell Heath.

3.12 The fabrik review then uses the development parameters in the WDC Green Belt Assessment to prepare a plan showing potential development capacity of the site (see Figure 5.4 in the fabrik review). The plan shows how:

 the boundary to the north of the site could be defined through advanced planting along the northern edge of the site, to provide a new Green Belt boundary and to set the proposed development in to a landscape structure consistent with the pattern of tree belts locally;

 the inclusion of a network of open spaces that protect the higher ground and maintains the landscape setting;

 the inclusion of 15m wide green buffers to the Oak Wood Copse, which is an Ancient Woodland;

 the development of the site, set on south facing slopes, would not result in a reduction of the actual or perceived gap between Flackwell Heath and High Wycombe; and would result in the rounding off of the settlement, not extending the existing visual envelope associated with Flackwell Heath; and

 on the basis that the BGBA definition of sprawl is the outward spread of a large built up area at its periphery in an untidy or irregular way, and having regard to the fact that Amersham College is located beyond and to the north of the Heath End Farm site, beyond which lies the M40 corridor, its development as proposed by Berkeley cannot amount to “sprawl”. It would in effect be the filling in of gap within the broader built up area of the settlement.

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3.13 Section 5.6 of the fabrik review shows also how the development parameters above address the five purposes of the Green Belt.

3.14 There are no further planning policy constraints to the site. The Environment Agency Flood Maps show the site to be entirely within Flood Zone 1 meaning it is at the lowest risk of flooding.

3.15 Safe access to the site can be obtained from Heath End Road.

4.0 LAND AT CHAPMAN LANE, BOURNE END

4.1 Bourne End is designated as a Tier 2 “Market Towns and Other Major Settlements” within the Plan’s settlement hierarchy. This means it is one of the main locations for sustainable development (second only to the District’s main urban area of High Wycombe). Policy CP3 – Settlement Hierarchy states that development will be directed towards Bourne End (and Wooburn) through land removed from the Green Belt that is identified in the Plan.

4.2 Land at Chapman Lane is an 8ha site on the northern edge of Bourne End and can be seen outlined in red on the plan found at Annex 4. Berkeley has control of the site and estimates that it could deliver circa 150 new homes.

4.3 The site is bounded to the east, west and south by existing residential development. Development on this site would not extend the built up area of Bourne End into open countryside and would be a sustainable, policy compliant (CP2 and CP3 from the Emerging Plan above) urban extension.

4.4 The site was considered in WDC’s Housing and Economic Land Availability Assessment November 2015 (HELAA) under site reference SBE0048 but was discounted because of its Green Belt location.

4.5 The fabrik review concludes that based on the inconsistencies of the approach in the WDC Green Belt Assessment (see section 2 of the fabrik review) the Land at Chapman Lane Bourne End should be also be considered for release from Green Belt.

4.6 The landscape analysis in the fabrik review explains that the site lies on south facing slopes, consistent with the existing developed edges of Bourne End and is currently in arable use.

4.7 The site has strong urban/sub urban edge influences to the south and east informed through a combination of built form associated with residential, commercial/utility and educational uses and therefore is varied in scale and mass. The site is not free from the influences of neighbouring urban development and it is an over generalisation in the WDC Green Belt Assessment to suggest that the site “feels largely rural in character”. Residential uses along the western edges of the site are apparent along Chapman Lane, but due to the intervening vegetation are less apparent from within the site.

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vegetation. Furthermore, there are measures that can be taken to ensure a future robust boundary is created in the long term (consistent with the approach to the Northern Heights proposed allocation) and hence the site is considered suitable for release from the Green Belt.

4.9 The Review then uses the development parameters in the WDC Green Belt Assessment to prepare a plan showing potential development capacity of the site (see Figure 5.1 in the fabrik review). The plan shows how:

 the northern boundary of the proposed development parcel could be defined through advanced planting, to provide a new Green Belt boundary and to set the proposed development in to a landscape structure consistent with the characteristic pattern of treebelts along the northern edge of Bourne End;

 the inclusion of a green corridor along the western edge of the development to maintain the green lane character of Chapman Lane and in consideration of the character of residential development to the west of Chapman Lane;

 the continuation of the green space beyond the site to the south into the southern section of the site in an area well related to the allotments;

 the retention of the land parcel to the north as agricultural land and therefore the development of the site as illustrated would not result in a reduction of the actual or perceived gap between Bourne End and Flackwell Heath; and would deliver a logical urban extension, not extending the visual envelope associated with Bourne End; and

 in relation to paragraph 4.4.8 of the BGBA relative to the definition of sprawl (the outward spread of a large built up area at its periphery in an untidy or irregular way), the development as illustrated would not represent sprawl. This is because it would not extend beyond the existing developed envelope of the settlement, especially considering the neighbouring residential land to the east.

4.10 Finally, paragraph 5.3 of the fabrik review shows how the development parameters above address the five purposes of the Green Belt.

4.11 There are no further policy constraints to the site. The Environment Agency Flood Maps show the site to be entirely within Flood Zone 1 meaning it is at the lowest risk of flooding.

5.0 LAND SOUTH OF MARLOW ROAD, WELL END

5.1 This site (WDC SHLAA Site SBE0043) is located outside the Green Belt and within the built up area. It is suitable and available for development and could accommodate around 100 homes. Its allocation would reduce further WDC’s reliance on AVDC in seeking to meet its OAN.

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6.0 SUMMARY AND CONCLUSION

6.1 AVDC is seeking in its Draft Local Plan to accommodate 33,300 new homes in the period to 2033. This figure includes 5,000 new homes, which equates to one third of WDC’s housing need, which it states it is unable to accommodate in its own district.

6.2 Even after considering suitable sites through its Housing Land Availability Assessment, AVDC can only find sites for 30,032 new homes (short by 3,268). Moreover, AVDC’s Draft Plan is proposing a new settlement (in an as yet undetermined location) and substantial growth at Aylesbury and on the edge of Milton Keynes. With long lead in times and local and strategic infrastructure issues which need to be resolved, it is extremely doubtful that AVDC will be able to deliver the high level of growth planned (more than a doubling of recent levels) within the plan period. This ultimately means that housing need in the HMA will not be met.

6.3 Linked to this, Berkeley believes that WDC has greater capacity within its own district to accommodate its own housing need and that consequently, it should not be seeking to overburden AVDC by expecting it to accommodate some of its own growth in its Draft Plan which is so ambitious that it is likely to fail.

6.4 Berkeley instructed Chartered Landscape Architects, fabrik, to review the BGBA and the WDC Draft Green Belt Part 2 Assessment which together form part of the evidence that support’s WDC’s contention that it has limited capacity for housing development within its own district.

6.5 Using WDC’s methodology, the fabrik review found that there is greater capacity in the Green Belt located within Wycombe District than has been stated by WDC.

6.6 As examples, sites at Flackwell Heath and Bourne End, which are under the control of Berkeley, and which are located on the edge of sustainable settlements (see WDC’s Settlement Hierarchy) perform well in the fabrik review.

6.7 Moreover, using the development parameters in the WDC Green Belt Assessment, the fabrik review contains a plan for each site showing potential development capacity.

6.8 In summary, AVDC has a Draft Plan which is at present unsound and undeliverable due to an overly ambitious, unachievable housing target. The Plan will lead to an under-delivery of housing in the HMA and potentially to the relevant Local Plans being found unsound. As a solution to the problem, Berkeley supports the need for additional housing capacity work to be undertaken in Wycombe District as part of the ‘Duty to Co-operate’.

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NEW WYCOMBE DISTRICT LOCAL PLAN 2033 DRAFT CONSULTATION

SUBMISSIONS ON BEHALF OF BERKELEY STRATEGIC LAND LIMITED

AUGUST 2016

Berkeley Strategic

1.0 INTRODUCTION

1.1 This submission is made in response to the new Wycombe District Council Local Plan - Draft Consultation Document (August 2016) (“the Draft Plan”). It is made on behalf of Berkeley Strategic Land Limited (“Berkeley”).

1.2 Berkeley has control of Abbey Barn South, which is identified in the Draft Plan under Policy HW5 – Abbey Barn South and Wycombe Summit as a site for residential led mixed use development.

1.3 Berkeley also has interests in two other sites in Flackwell Heath and Bourne End, which it is putting forward for consideration as allocated housing sites.

1.4 The comments set out hereunder follow the structure adopted in the Plan. They also have regard to a Green Belt Review, commissioned by Berkeley, which has been undertaken by Chartered Landscape Architects, fabrik (“the fabrik review”). The fabrik review relates specifically to the case that Berkeley makes in relation to the greater capacity available in Wycombe’s Green Belt and the sites at Flackwell Heath and Bourne End.

2.0 NEW LOCAL PLAN 2033

Background

2.1 The Draft Plan covers the period 2013 – 2033 and sets out a spatial strategy for the delivery of some 10,000 new homes over the Plan period.

2.2 The Draft Plan has been informed by the Buckinghamshire Housing and Economic Development Needs Assessment 2016 (HEDNA). The HEDNA looked at housing need within the Buckinghamshire Housing Market Area (HMA), which includes Aylesbury Vale, Chiltern, South Bucks and Wycombe Districts. The housing need in Wycombe District was found to be 15,100 over the Plan period.

2.3 The Plan however does not provide for the full housing need (15,100 new homes). Policy CP2 – Spatial Strategy states the Council will deliver broadly two thirds of the District’s housing need and that the Council will work with Aylesbury Vale District Council through the Duty to Cooperate to accommodate unmet need.

2.4 Aylesbury Vale District Council (AVDC) is currently consulting on its Vale of Aylesbury Local Plan 2033. That Plan makes reference to the need to accommodate some of Wycombe’s unmet need. Berkeley will also be making representations in respect of that Plan.

The Spatial Strategy

2.5 On the basis that the Council’s working assumption is that AVDC’s emerging Plan will be delivering approximately one third of Wycombe’s objectively assessed need (OAN), any assessment of the robustness/deliverability of the

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Wycombe Local Plan must at the same time consider the robustness/deliverability of the AVDC Plan. This we do below.

Vale of Aylesbury Draft Local Plan 2033

2.6 The Buckinghamshire HEDA identifies a housing need in AVDC of some 21,300 homes over the Plan period. The draft AVDC Local Plan seeks to identify enough land to meet this need plus an additional 5,000 homes to meet Wycombe’s unmet need and a proportion of the unmet need from Chiltern District and South Bucks District Council. This has resulted in an AVDC “Spatial Strategy for Growth” (Policy S2) that seeks to deliver 33,300 over the plan period (2013 – 2033) or 1665 dwellings per annum (dpa).

2.7 AVDC’s most recent 5-year housing land supply position statement (January 2016) shows that between 2001 and 2015 an average of 817 dpa were completed across the district. This is less than half the figure proposed in the emerging Local Plan. Moreover, that statement identifies that there is already a shortfall of 921 completions for the first two years of the Plan. In addition, the housing trajectory in the statement appears to show that the Plan will be back-loaded with the more completions towards the end of the plan period, which must raise concerns over delivery.

2.8 Table 1 - Spatial Strategy for Growth in Aylesbury Vale, which can be found at page 32 in the AVDC Draft Plan, shows that even after considering potential sites through its Housing Land Availability Assessment, AVDC is short of suitable sites to accommodate 3,268 dwellings of the 33,300 dwelling target. This raises serious question marks as to the ability of the emerging AVDC Draft Plan to absorb the additional homes required to meet Wycombe’s unmet need.

2.11 Berkeley notes that the AVDC Draft Plan includes a proposal for a new settlement of some 6,000 new homes, 4,500 of which are to be provided in the plan period. Two possible locations have been highlighted: Haddenham and Winslow. If AVDC has yet to decide on a preferred location for the new settlement, it is again difficult to see how it will have an adopted Plan in place by next year, and how the new settlement can deliver 4,500 homes in the Plan period.

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2.12 AVDC is also planning to build over 8,000 new homes dwellings at Aylesbury (this is in addition to the existing 5,419 dwellings in the pipe-line from existing allocated sites and other developable sites) and over 4,000 on sites adjacent to Milton Keynes.

2.13 The current version of the AVDC Plan does not allocate specific sites in Aylesbury (potential sites are identified) but states at paragraph 4.12 that, where possible, development will be located at suitable previously developed sites in the existing Aylesbury urban area to regenerate the town. The remainder will be linked into sustainable urban extensions on greenfield sites around the town.

2.15 Seeking to accommodate some 8,000 new homes on large strategic sites on the edge of Aylesbury and on brown field sites within the town also raises a market saturation issue and is likely to result in developers progressing more slowly than would be the case if AVDC had chosen to adopt a more dispersed strategy with a larger number of smaller sites spread around the district’s larger settlements.

2.16 These factors bear significantly on the ability of the AVDC Draft Plan to deliver the number of homes anticipated in the plan period. More importantly, they call in to question the very soundness of the Plan as drafted. There are similar issues with development on sites adjacent to Milton Keynes.

2.17 In addition to these spatial planning issues, the timely delivery of wider infrastructure projects will be key to AVDC meeting its ambitious housing targets. Paragraph 3.44 of the AVDC’s draft plan highlights East–West Rail and the A421 expressway as two such key infrastructure projects.

2.18 East-West Rail is a strategic railway connecting East Anglia with Central, Southern and Western England with stops at Oxford, Aylesbury and Winslow. The project was initially due to be built in two phases with completion by March 2019. This has slipped considerably. Following a consultation by Network Rail in 2015, it proposed that the route should now be built in three phases (western, central and eastern phases). Network Rail has only recently announced a preferred route for the eastern section. As such, there are clear timing issues with the full east to west delivery of this key piece of infrastructure, which is inextricably linked to the ambitious housing growth proposed by AVDC.

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‘exploratory’ stages of its investment questioning the ability for the route to be delivered within the plan period.

2.22 The above demonstrates how AVDC’s Plan, as drafted, will not deliver the level of housing proposed. This in turn means that the housing need for the HMA will not be met and that the Plan will likely be found unsound. Berkeley will be submitting detailed representations on the AVDC Plan to set out this position in full.

New Wycombe District Local Plan

2.23 The above analysis shows that there is a very strong likelihood that AVDC will be unable to deliver around one third of Wycombe District’s OAN in the period to 2033. This in turn calls in to question the soundness of WDC’s spatial strategy as set out in its Draft Plan. The solution is for the Council to look again at the options for meeting its OAN on land within its own boundaries, including land in the Green Belt. Such an approach would be consistent with the Plan’s vision, which is:

“Wycombe District: economically strong and the place to live work and visit.” (our emphasis)

2.24 Policy CP2 – Spatial Strategy of the Plan states that:

“The Council will, through the allocations and policies in the Plan:

…..

It then states at paragraph 4.28 in the Plan that the Council has “thoroughly reviewed the scope for meeting its housing needs within the district” and that that review has included “reviewing the scope for removing areas of land from the Green Belt where it would not be significantly harmful to the purposes of the Green Belt.”

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Berkeley Strategic

2.25 Berkeley would question the thoroughness of the Council’s review of sites in the Green Belt. Berkeley’s considered view is that there are additional sites in the Green Belt that have “weak Green Belt functions” and which should be allocated for housing development thereby reducing the reliance on AVDC and improving the chances that both plans will be found to be ‘sound’.

Berkeley’s Green Belt Study

2.26 Berkeley has commissioned fabrik Chartered Landscape Architects to carry out a more detailed review of the Buckinghamshire and Wycombe Green Belt Studies which act as background evidence for Wycombe’s Local Plan. The fabrik review demonstrates that there are additional sites within the Green Belt that could be brought forward for development to meet more fully the Council’s OAN. It also demonstrates that there are inconsistencies in the approach taken in the Buckinghamshire Green Belt Assessment. Moreover, there are a number of additional sub-areas within the General Areas that warrant further consideration but which have not been included in the Assessment.

2.27 In terms of the Wycombe District Council Draft Green Belt Part 2 Assessment, again, there is an inconsistent approach to the assessment of the individual sites. The identification of sites proposed for Green Belt release is therefore challenged in the fabrik review. There are a number of similarities to be drawn between the proposed Green Belt releases in Wycombe District and the Berkeley sites. The objective landscape analysis of the two Berkeley sites at Flackwell Heath and Bourne End in the fabrik review concludes that the Berkeley sites could come forward and deliver development in a manner which maintains the relevant 3 purposes of the Green Belt in a consistent way to the other sites proposed by Wycombe District Council. The fabrik review can be found at Annex 1.

2.28 It is clear from the fabrik review that using Wycombe’s methodology for assessing sites within the Green Belt there is a greater capacity for further development than is acknowledged in the Plan. This means that the level of unmet housing need that AVDC is expected to accommodate is too high. As explained above, it is unlikely the AVDC will be able to provide for its own housing need, let alone the unmet needs of Wycombe, Chiltern District and South Bucks District Councils. It follows therefore that Wycombe should use the extra capacity to help in meeting its own housing need.

3.0 HEATH END FARM, FLACKWELL HEATH

3.1 Flackwell Heath is designated as a Tier 3 “Higher Order Service Village” within the Plan’s settlement hierarchy. This means it has a number of key services and facilities and is considered a sustainable location for development. Policy CP3 – Settlement Hierarchy states that development will be directed towards Tier 3 and 4 villages through limited land removed from the Green Belt as identified in the Plan.

3.2 Policy CP4 – Delivering Homes in the Plan states that WDC is seeking to deliver 1,100 homes across the rural areas with a focus on the larger and medium sized villages.

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Berkeley Strategic

3.3 Heath End Farm is a 5.2ha site on the edge of Flackwell Heath and can be seen outlined in red on the plan at Annex 2. Berkeley has control of the site and estimates that it would deliver circa 100 new homes.

3.4 The site is bounded on three sides by existing development and by Oak Wood Copse, which is an area of Ancient Woodland: there is residential development to the east and south; Amersham & Wycombe College to the west; and the Copse to the north-east. As such, the site’s development would not extend the built up area of Flackwell Heath into open countryside and would represent a sustainable, policy compliant (CP2, CP3 and CP4 above) urban extension.

3.5 The site was considered in WDC’s Housing and Economic Land Availability Assessment November 2015 (HELAA) under site reference SWC0070. However, it was discounted due to its Green Belt location.

3.8 The site lies between the existing developed edges associated with Flackwell Heath. Amersham College is identified as a Major Developed site in the Green Belt. This site, together with its associated grounds (which include floodlighting) and neighbouring uses together form the western edge of Flackwell Heath. Amersham College is clearly visible passing Spring Lane on Heath End Road, especially travelling west. The site includes Heath End Farm and associated buildings.

3.9 The southern edge of the site is influenced by the adjacent residential uses to the south of Heath End Road. There are a series of defensible boundaries present, the ridgeline and the M40 to the north; the woodland to the east; Heath End Road to the south; and Spring Lane to the west. The ribbon of residential development to the south of the site influence the southern edge of the site. The presence of Heath End Farm is apparent when travelling south along Spring Lane.

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Berkeley Strategic

 the inclusion of a network of open spaces that protect the higher ground and maintains the landscape setting;

 the inclusion of 15m wide green buffers to the Oak Wood Copse, which is an Ancient Woodland;

 on the basis that the BGBA definition of sprawl is the outward spread of a large built up area at its periphery in an untidy or irregular way, and having regard to the fact that Amersham College is located beyond and to the north of the Heath End site, beyond which lies the M40 corridor, its development as proposed by Berkeley cannot amount to “sprawl”. It would in effect be the filling in of gap within the broader built up area of the settlement.

3.13 Section 5.6 of the fabrik review shows also how the development parameters above address the five purposes of the Green Belt.

3.14 Berkeley is aware that Oak Wood Copse has been nominated for inclusion on the list of Assets of Community Value. As part of any discussion about the release of the Heath End site from the Green Belt, Berkeley and the landowner would be prepared to explore the possibility of vesting the copse with the local community and making a contribution by way of a commuted sum to its future upkeep.

3.15 There are no further planning policy constraints to the site. The Environment Agency Flood Maps show the site to be entirely within Flood Zone 1 meaning it is at the lowest risk of flooding.

3.16 Safe access to the site can be obtained from Heath End Road.

4.0 LAND AT CHAPMAN LANE, BOURNE END

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Berkeley Strategic

states that development will be directed towards Bourne End (and Wooburn) through land removed from the Green Belt that is identified in the Plan.

4.2 Land at Chapman Lane is an 8ha site on the northern edge of Bourne End and can be seen outlined in red on the plan found at Annex 3. Berkeley has control of the site and estimates that it could deliver circa 150 new homes.

4.4 The site was considered in WDC’s Housing and Economic Land Availability Assessment November 2015 (HELAA) under site reference SBE0048 but was discounted because of its Green Belt location.

4.6 The landscape analysis in the fabrik review explains that the site lies on south facing slopes, consistent with the existing developed edges of Bourne End and is currently in arable use.

4.7 The site has strong urban/sub urban edge influences to the south and east informed through a combination of built form associated with residential, commercial/utility and educational uses and therefore is varied in scale and mass. The site is not free from the influences of neighbouring urban development and it an over generalisation in the WDC Green Belt Assessment to suggest that the site “feels largely rural in character”. Residential uses along the western edges of the site are apparent along Chapman Lane, but due to the intervening vegetation are less apparent from within the site.

4.8 The majority of the site boundaries are robust in NPPF terms (applying the same principles that WDC has used on other sites): they are defined by landscape designations, existing built form, allotments, road corridors or vegetation. Furthermore, there are measures that can be taken to ensure a future robust boundary is created in the long term (consistent with the approach to the Northern Heights site) and hence the site is considered suitable for release from the Green Belt.

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Berkeley Strategic

 the continuation of the green space beyond the site to the south into the southern section of the site in an area well related to the allotments;

4.10 Finally, paragraph 5.3 of the fabrik review shows how the development parameters above address the five purposes of the Green Belt.

4.11 There are no further policy constraints to the site. The Environment Agency Flood Maps show the site to be entirely within Flood Zone 1 meaning it is at the lowest risk of flooding.

5.0 LAND EAST OF OLD HORNS LANE, BOOKER

5.1 This site (SHLAA Site SHW0529) is proposed for release from the Green Belt under Policy CP9 and HW15. This is on the basis of the WDC Green Belt Assessment, which identifies the site as being suitable for employment use. Appendix C of the draft Plan identifies the site as a potential traveller site. This proposed use is not supported by the landowner who has submitted a separate representation supporting employment use on the site. Berkeley supports the landowner’s case as set out in that submission.

6.0 LAND SOUTH OF MARLOW ROAD, WELL END

6.1 This site (SHLAA Site SBE0043) is located outside the Green Belt and within the built up area. It is suitable and available for development and could accommodate around 100 homes. Its allocation would reduce further the Council’s reliance on AVDC in seeking to meet its OAN.

Wycombe District New Local Plan Consultation August 2016 9

Berkeley Strategic

7.0 POLICY HW5 – ABBEY BARN SOUTH AND WYCOMBE SUMMIT

7.1 Berkeley has control over the land known as “Abbey Barn South” and supports WDC’s allocation of the site in its Plan. Having worked closely with the Council on the now approved development Brief, Berkeley is intending to bring forward an early planning application. This will enable the delivery of houses early in the Plan period.

7.2 Policy HW5 – Abbey Barn South and Wycombe Summit sets out the requirements for the site’s mixed use development. Berkeley is broadly supportive of this policy but would suggest the following minor modifications (shown in red below)

POLICY HW5 – ABBEY BARN SOUTH AND WYCOMBE SUMMIT

The site is allocated for residential led mixed use development comprising Residential, Business and associated Community Uses.

Development of the site is required to:

1. Placemaking

a) Respond positively to the site and its surroundings to create a distinctive sense of place, resulting in the Daws Hill development, the Abbey Barn South development and the ski slope development functioning as one place in terms of connectivity, open space and other facilities and which physically and visually integrates with its surroundings. The Council acknowledges that the Abbey Barn South and the former ski slope site are in separate ownership and that they will be the subject of separate planning applications.

b) Improve public accessibility to the Ride and Deangarden and Keep Hill Woods.

c) Subject to demand and viability, Pprovide a minimum of 1.6 ha of land for employment uses (B1 or B8) and be located on the south western corner of the site, adjacent to the area permitted for employment development on the neighbouring Daws Hill development, with access from that development.

2. Transport:

a) Provide a satisfactory vehicular access from Abbey Barn Lane to each site which respects the important adjacent Green Belt, and the setting of the Listed Buildings’ to the east settings to the East and landscape sensitivity in views to/from the north.

b) Provide a spine road through the site road linking the Daws Hill development to Abbey Barn Lane.

c) Provide a pedestrian/cyclists crossing on Abbey Barn Lane.

d) Provide for footpaths, cycleways and bridleways through the area including new links within Deangarden Wood and a footway to Abbey Barn

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Berkeley Strategic

North (the latter to be provided as part of the Wycombe Summit development).

e) Provide an appropriate footpath/cycleway network connecting with:

i. routes proposed to Handy Cross Hub, ii. the existing route linking Daws Hill and Keep Hill Road and iii. Amersham and Wycombe College at Flackwell Heath.

f) Provide footpath/cycleway links within the site and the footpath/cycleway to Flackwell Heath beside Heath End Road.

g) Connect the bridleways through Keep Hill Wood and the Abbey Barn Lane shared pedestrian path/cycle lane to Winchbottom Lane. This would complement access to the unclassified road running northsouth, west of Winchbottom Lane.

h) Upgrade footpath LMA/22 to the bridleway allowing cycling access to this lane.

i) Provide a signalised or upgraded bridge on Abbey Barn Lane

3. Open space

a) Retain the Ride as shown on the Policies Map as an area of semiformal public open space.

b) Remove man-made structures from the ski slope and landscape the slope to improve its visual appearance and biodiversity and allow public access to the slope.

c) Relocate the baseball ground to an appropriate off-site location if necessary.

4. Green Infrastructure/Environment

a) Provide an area of green infrastructure network to link the Ride to Deangarden Wood and which can function as an ecological corridor.

b) Manage and maintain the Ride and Deangarden Wood to retain their landscape character and maximise their biodiversity value.

5. Landscape

a) Provide new tree planting to create a wooded skyline and a sylvan character when viewed from within and across the valley.

b) Keep building heights substantially below the existing ridge top tree line of the Ride and new wooded skyline to avoid intruding upon views of the area from the wider landscape.

c) Protect the most visually-sensitive part of the site (the eastern quarter of Abbey Barn South) through use of lower density and building heights while

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Berkeley Strategic

retaining existing trees and providing new tree planting.

d) Screen views of development at Wycombe Summit from across the valley keeping building heights below the existing and new tree line on the horizon and through new tree planting close to the boundary with Abbey Barn South.

6. Other

a) Fully consider motorway noise in the design and layout of the development, and provide any appropriate mitigation measures.

b) Contribute towards delivering the Wycombe Reserve Sites Infrastructure Delivery Plan.

7.3 With regard to criteria g and h above these requirements relate to the provision of footpath and cycle connections to Winchbottom Lane and an existing track to the west which is not a public right of way. These links are not required to make the development acceptable and it is questioned whether it is right that these routes are being encouraged as recreational routes given that Winchbottom Lane is a narrow road with no footpaths and the track to the west is a private road and not a public right of way. Berkeley would therefore request that these criteria are removed.

8.0 POLICY DM24 – AFFORDABLE HOUSING

8.1 Berkeley objects to proposed Policy DM24 – Affordable housing, which seeks affordable housing as a percentage of Gross Internal Area. As drafted, this policy is unduly onerous and detrimental to the viability and ultimately the delivery of much needed housing in the District.

8.2 Existing Policy CS13 in the adopted Core Strategy 2008 seeks affordable housing as a percentage of bed spaces. This has proved burdensome in itself but the policy is caveated by stating that the requirement is “subject in every case to the physical circumstances of the site and prevailing and anticipated market conditions”.

8.3 No such caveat appears in draft Policy DM24. It is essential that WDC remains flexible in its approach to affordable housing whereby its provision has regard to the physical circumstances of each site (including on and off site infrastructure costs) and market conditions if it wishes to achieve its housing targets.

8.4 It is also unclear from the policy and the supporting text how this requirement fits with the Government’s policy of requiring local planning authorities to provide ‘Starter Homes’ under the Ministerial Statement which states:

“Local planning authorities should work in a positive and proactive way with landowners and developers to secure a supply of sites suitable for housing for first- time buyers.”

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Berkeley Strategic

9.0 SUMMARY AND CONCLUSION

9.1 AVDC is seeking in its Draft Local Plan to accommodate 33,300 new homes in the period to 2033. This figure includes 5,000 new homes, which equates to one third of Wycombe District Council’s housing need, which it states it is unable to accommodate in its own district.

9.2 Even after considering suitable sites through its Housing Land Availability Assessment, AVDC can only find sites for 30,032 new homes (short by 3,268). Moreover, AVDC’s plan is proposing a new settlement and substantial growth at Aylesbury. With long lead in times and local and strategic infrastructure issues, it is extremely doubtful the AVDC will be able to deliver the high level of growth planned within the plan period. This ultimately means that housing need in the HMA (including Wycombe’s housing need) will not be met.

9.3 Berkeley believe that Wycombe District Council has greater capacity within its own district to accommodate its own housing need and that consequently, it should not be seeking to overburden AVDC by expecting it to accommodate some of its own growth in a Plan that is so ambitious that it is likely to fail.

9.4 Berkeley instructed Chartered Landscape Architects fabrik to review the BGBA and the WDC Green Belt which together form part of the evidence that support’s Wycombe’s contention that it has limited capacity for housing development within its own district.

9.5 Using Wycombe’s methodology, the fabrik review found that there is greater capacity in the Green Belt located within Wycombe District than has been stated by the Council.

9.6 Sites at Flackwell Heath and Bourne End, which are under the control of Berkeley, and which are located on the edge of sustainable settlements (see Wycombe’s Settlement Hierarchy) perform well in the fabrik review.

9.7 Using the development parameters in the WDC Green Belt Assessment, the fabrik review contains a plan for each site showing potential development capacity.

9.8 Berkeley has control over the land known as “Abbey Barn South” and, subject to the relatively minor modifications listed in section 5 above, supports WDC’s allocation of the site in its Plan under Policy HW5 – Abbey Barn South and Wycombe Summit.

9.9 Berkeley objects to proposed Policy DM24 – Affordable housing, which seeks affordable housing as a percentage of Gross Internal Area. As drafted, this policy is unduly onerous and detrimental to the viability and ultimately the delivery of much needed housing in the District. It is also unclear from the policy and the supporting text how this requirement fits with the Government’s policy of requiring local planning authorities to provide ‘Starter Homes’ under the Ministerial Statement.

Wycombe District New Local Plan Consultation August 2016 13 Annex 2 – The fabrik Green Belt Review Landscape Representations to Buckinghamshire and Wycombe District Council Green Belt Study

Job No. D2440 July 2016 - Rev B Landscape Representations Land at Bourne End and Flackwell Heath

Contents

1. Executive Summary...... 3

2. Introduction....... 4

3. Landscape Critique of the Buckinghamshire Green Belt ...... Assessment...... 5

4. Landscape Critique of the Wycombe Green Belt Part 2 Site .. Assessment...... 10

5. Landscape Analysis and Landscape Development ...... Parameters...... 14 5.1 Landscape Analysis of Land at Chapman Lane, Bourne End...... 14 5.2 Landscape Development Parameters...... 17 5.3 Meeting the Green Belt Purposes...... 18 5.4 Landscape Analysis of Land at Heath End Road, Flackwell ... Heath...... 19 5.5 Landscape Development Parameters...... 23 5.6 Meeting the Green Belt Purposes...... 24

6. Conclusion...... 25

2 Landscape Representations Land at Bourne End and Flackwell Heath

1. Executive Summary

fabrik Chartered Landscape Architects have been appointed by together with 4 appendices. The WDC assessment has considered 3 Berkeley Strategic Land Limited (Berkeley) to carry out a review of categories of sites for assessment, including the sub areas identified the Buckinghamshire Green Belt Assessment (GBA) March 2016, in the Part 1 Assessment; developer promoted sites; and wider sense prepared by Arup and the Wycombe District Council (WDC) Draft check sites. Of particular note to this representation is Appendix 3 - Green Belt (GB) Part 2 Site Assessment, June 2016, relative to Development Capacity of Green Belt Residential Sites; and Appendix landscape and visual matters. 4 - Individual Site Assessments.

Berkeley has interests in sites north of Heath End Road, Flackwell The Berkeley sites are identified as SBE0048 - Land east of Heath and east of Chapman Lane, Bourne End. Berkeley have put Chapman Lane, Bourne End and SWC0070 - Land north of Heath forward these two sites for consideration as allocated housing sites End Road, Flackwell Heath and have been included as part of the site (and have been considered in the WDC GB Part 2 Assessment). assessments in Appendix 4.

The GBA contains 6 sections and includes, amongst others, sections In terms of the WDC Part 2 Assessment, there is an inconsistent on policy, guidance and experience; methodology; key findings; approach to the assessment of the individual sites. The identification and recommendations. The GBA tests the General Areas (GA) of sites proposed for Green Belt release is therefore challenged. relative to the 5 purposes of the Green Belt. In many cases only 3 of the 5 Green Belt purposes apply, of the 3, these relate to checking An objective landscape analysis of the Chapman Lane and Heath unrestricted sprawl of large built up areas (purpose 1); preventing End Road sites has been carried out and has informed the landscape neighbouring towns from merging (purpose 2); and safeguarding the led development parameters plan. The assessment and plans have countryside from encroachment (purpose 3). been prepared considering the sites inherent landscape sensitivities and how these sites perform under the Green Belt purposes. These Within the GBA, the Flackwell Heath site lies in GA 46b and the have been prepared to be directly comparable to the development Bourne End site in GA 52a. The GBA assesses that both of these capacity plans in Appendix 3 of the WDC Assessment. GA strongly meet the Green Belt purposes (although not all of the purposes are applicable). The majority of the GA have a strong or Overall, it is considered that both the Berkeley sites could come medium score against all five of the Green Belt purposes, with only 2 forward to deliver development in a manner which maintains the of the GA having a weak score. relevant 3 purposes of the Green Belt beyond the site boundaries and therefore could be released from the Green Belt in a consistent way The GBA identifies sub areas within the GA for consideration in Part to the other sites proposed by Wycombe District Council. 2 of the Green Belt study. Neither GA 46b or 52a have been identified to include sub-areas.

There are a number of inconsistencies in the approach within the GBA in terms of identifying sub areas and it is considered that a number of additional sub-areas within the GA warrant further consideration.

The WDC GB Part 2 Assessment includes, amongst others, sections on scope of sites assessed; and the findings of the assessment,

3 Landscape Representations Land at Bourne End and Flackwell Heath

2. Introduction

2.1 Introduction Legend High Wycombe fabrik Chartered Landscape Architects have been appointed by Site Promotion Areas Berkeley Strategic Land Limited (Berkeley) to carry out a review of the Buckinghamshire Green Belt Assessment, March 2016 (GBA) prepared by Arup and the Wycombe District Council (WDC) Draft Green Belt Part 2 Site Assessment, June 2016, relative to landscape and visual matters M40 Berkeley has interests in sites at Flackwell Heath and Bourne End, the location and extent of which are shown on the plan opposite. Berkeley have put forward these two sites for consideration as allocated housing sites (and have been considered in the WDC Part 2 Assessment).

This document:

• provides a landscape critique of both the GBA and WDC Part 2 Flackwell Heath documents;

• sets out a brief landscape and visual appraisal of the two Berkeley sites;

• proposes landscape led development parameters, illustrating how the sites could be developed, whilst maintaining the wider Green Belt purposes (consistent with the WDC approach in Appendix 3 of their document); and

• demonstrates the suitability of the sites, in landscape and visual terms, for development and that these therefore should be included in the list of proposed Green Belt releases. Bourne End

Figure 1.1 – Extract from Ordnance Survey Plan showing the location of the Berkeley promotion sites (fabrik, 2016)

4 Landscape Representations Land at Bourne End and Flackwell Heath

3. Landscape Critique of Buckinghamshire Green Belt Assessment

A3 17 9a 18a Introduction 18b Legend 19 16a 16c Legend ! 9h 14a Dacorum ° 9c The key areas of interest for Berkeley relate to General Areas 46b 21a Chiltern 22b Berkeley site locations 22a General Areas 9f District 14b (relative to the land interest at Flackwell Heath) and 52a (relative to 9g 23a the land interest at Bourne End) identified in the Buckinghamshire Neighbouring District 25b 24b 23b Green Belt Assessment, March 2016 (GBA) prepared by Arup. The 21b 31 30 35 28 20 Wycombe 27 location and extent of these sites and GA are shown on the plan 24a 29 Buckinghamshire District 26 District 33e opposite. 33b 25c Three 34 25a 36 Rivers Buckinghamshire County 112 The following paragraphs set out the key landscape and visual points 33a 32a of note in the GBA (and in particular relative to the areas of Berkeley 33c Buckinghamshire Green Belt interest; those land parcels within Wycombe District Council only and 37 33d 38b 39 Neighbouring Green Belt those which have similar landscape characteristics to the Berkeley High Wycombe 38a land parcels). 32b 41b 43a 114 42 113 41a Section 2 Policy, Guidance and Experience 43b 45 44b 46b 49a 48 47a Paragraph 2.3.3 under Purpose 2: to prevent neighbouring towns 43c 47b 57a 53b 44a from merging into one another, the final paragraph sets out that: 46a 49b 53a 40b 51 43e 55 57b “Landscape character assessment is a useful analytical tool for this 52a type of assessment.” However, whilst the Townscape Assessment 52b 54 50a 62 40a has been used to assist the assessment relative to Purpose 4, it is 43d 56 61 60 111 64a 63 not documented in the GBA how the Buckinghamshire Landscape 59 65a Contains Ordnance Survey data © Crown copyright and database right 2013 Character Assessment has been used as a tool to assist in assessing Marlow 58b 66 58a 64b 65b 50b 67 69 the landscape relative to purpose 2. P1 13-01-16 CG ML AB 70 68 77 78 72 71 75 Issue Date By Chkd Appd Paragraph 2.5.4 goes on to say under bullet point 1 that: “A Green 74 76 South Belt Assessment is not an assessment of landscape quality, Bucks 79 Metres though elements of landscape assessment assist in assessing the District 0 1,550 3,100 6,200 80b 82 Hillingdon Green Belt (for example, in identifying potential new boundaries or 73 81 86b differentiating between areas of unspoilt countryside or semi-rural 85a 85b 87a areas).” There is no robust evidence setting out the information 84 80a 86a 83 gathered as part of the assessment, if carried out at all. South 89 Oxfordshire 88 87b 92 13 Fitzroy Street 90 Slough 93 London W1T 4BQ Under Purpose 3: to assist in safeguarding the countryside from 91 94 Tel +44 20 7636 1531 Fax +44 20 7580 3924 96 95 www.arup.com encroachment, the last paragraph states: “The recommended 98 97 Client approach is to look at the difference between land under the 99 The Buckinghamshire Authorities influence of the urban area and open countryside, and to favour open 100 countryside when determining the land that should be attempted to Windsor and be kept open, accounting for edges and boundaries.” fabrik concur Figure 3.1 – Extract from Buckinghamshire GBA Map 4.3b showingMaidenhead General Areas in the southern section Job Title of Buckinghamshire (Arup, March 2016) with this statement. Buckinghamshire Green Belt Assessment

Wokingham

Map 4.3b General Areas, South 5 Hounslow Reading Bracknell Spelthorne Scale at A3 Forest 1:115,000

Job No Drawing Status Runnymede 242368-00 Issue

Drawing No Issue 4.3b P1

3. Landscape Critique of Buckinghamshire Green Belt Assessment

Section 4 Methodology and which may be suitable for further consideration. The document forms the basis for maintaining the existing settlement pattern.” fabrik doesn’t set out how these smaller sites were selected. Whilst the disagree with this statement. The second purpose of the Green Belt is Paragraph 2.1.10 sets out the requirements of para 85 of the NPPF assessment (under Section 2, Policy, Guidance and Experience) wholly about coalescence not settlement pattern. Any development in terms of defining boundaries. The last bullet points recommends rightly identifies reserve locations for future development relative to coming forward will need to demonstrate how continued separation of to: “Define boundaries clearly; using physical features that are readily Wycombe District Councils Core Strategy (Adopted 2008) a number settlements is achieved. recognisable and likely to be permanent.” The Arup methodology of sites have also been considered in the Part 2 Assessment based at paragraph 4.3.3 sets out that: “Any potential alterations to the on sites promoted for development. As part of a comprehensive GA 46b lies adjacent to Flackwell Heath and 52a adjacent to Bourne Green Belt must be based on a new permanent and defensible assessment, the land promotions should have been included as part End as identified in Table 4.2 - Settlements Considered in Purpose boundary; thus permanent man-made and natural features were of the assessment. 2 Assessment (p 56). GA 46b scores 5 and is therefore deemed selected as the initial basis of criteria for the identification of ‘General to provide an ‘essential gap’. However, the eastern part of this GA Areas.’” Paragraph 4.3.5 then sets out a further refinement of these Purpose 1 Assessment: To check the unrestricted sprawl of includes the existing Major Developed Site in the Green Belt of boundaries to include unclassified public roads and private roads; large built-up areas Amersham College which defines the western developed fringes smaller water features; prominent physical features (e.g. ridgelines); of Flackwell Heath. In our opinion, the score for this area needs to existing development with a strongly established, regular or This relates to checking the unrestricted sprawl of large built-up provide a balance and therefore does not wholly meet this criteria. GA consistent boundaries; protected woodland and hedgerows. areas. (Emphasis added). 52a also scores a 5, although again, there are parcels within this area that sit between developed areas and therefore do not form part of Whilst it is understood that this is a Green Belt assessment, there Only the western tip of GA 46b lies on ‘the edge’ (paragraph 4.4.8, a wider ‘essential gap’. The outcome of the assessment is therefore is no consideration of any wider national or local level landscape sub section a) of the large built up area of High Wycombe as set questioned. designations, such as Areas of Outstanding Natural Beauty (AONB) out in Table 4.1 (p 51). GA 46b actually lies to the south of the M40 or Local Landscape Areas (LLA). These designations provide road corridor, which is considered to be a significant defensible Whilst Paragraph 2.3.3 sets out that: “Landscape character a further tier of constraint and merit consideration as part of the boundary to High Wycombe relative to the methodology. However, assessment is a useful analytical tool for this type of assessment”, assessment of boundaries. This should be a material consideration in Table 5.1 (p 79) GA 46b PASSES this test (and is given a score of there is no evidence setting out how or whether the Buckinghamshire as providing a defensible boundary in planning terms. 3 which relative to the criteria on table at p 53 states that the: “Land Landscape Character Assessment has been used as a tool to assist parcel is connected to one or more large built-up area(s), though the in the assessment. The assessment therefore fails to meet its own Assess General Areas sub-section large built-up area(s) is/are predominantly bordered by prominent, methodology. permanent and consistent boundary features”. It is questionable Paragraph 4.4.3 sets out that: “A score out of five was attributed for that all of the land parcel is therefore connected to the large built up The criteria provides a 4 point scoring mechanism for this section each criterion (Figure 4.2)... If a General Area was considered to areas. (using 0, 1, 3 and 5) which is at odds with the overall scoring system. have no contribution to a specific purpose, a statement was added to the pro-forma to this effect and a score (a score of zero) was The criteria provides a 6 point scoring mechanism for this section Purpose 3 Assessment: To assist in safeguarding the attributed.” However, what is actually assessed under each of the (including 1, 1+, 3, 3+, 5 and 5+). The use of this scoring mechanism countryside from encroachment Purposes varies between using a 4 and 6 point scale and includes has not been justified rather than simply using a scale of 0-5 as set ‘+’ criteria not included in Figure 4.2 and supporting text. The out in paragraph 4.4.3. Paragraph 4.4.21 states that: “Openness refers to the extent to which assessment therefore does not follow the scoring mechanism set out Green Belt land could be considered open from an absence of built in Figure 4.2. Purpose 2 Assessment: To prevent neighbouring towns merging development rather than from a landscape character perspective, into one another where openness might be characterised through topography and Paragraph 4.4.5 sets out that there may be small sub areas within the presence or otherwise of woodland and hedgerow cover.” General Areas (GA) that strongly meet the purposes of the GB which Para 4.4.16 states relative to ‘preventing neighbouring towns merging have the potential to score differently to the different areas as a whole into one another’ that in addition to preventing coalescence, “it also

6 Landscape Representations Land at Bourne End and Flackwell Heath

3. Landscape Critique of Buckinghamshire Green Belt Assessment

Purpose 3 Assessment: To assist in safeguarding the Section 5 Key Findings information setting out a balance of the different factors, all aspects countryside from encroachment (continued) are given equal weighting. Purpose 1 Findings: Paragraph 5.1.2 states that: “52 of the 157 GA 46b scores 5 which under para 4.4.25 possess a: “Strong unspoilt Green Belt General Areas (33%) do not lie at the edge of an identified Figure 4.2 sets out the Criteria Scores (p 50) relative to each of the rural character” and is “defined as land with an absence of built large built-up area and do not directly prevent sprawl, thus failing to purposes, although not all of the scores have been used under each form and characterised by rural lands uses and landscapes.” The meet Purpose 1. While some of these General Areas abut the edges of the purposes (in particular point 2 is not included as part of the assessment fails to acknowledge that the eastern edge of the area of settlements, they play no role in preventing the sprawl of ‘large criteria for Purposes 1, 2 and 4). There is an inconsistent approach includes the Major Developed Site in the Green Belt of Amersham built-up areas’ ...” However, whilst the assessment rightly identifies therefore to the scoring mechanism. College and any of the adjacent outlying buildings. The assessment GA 52a as failing the Purpose 1 test, as GA 46b lies to the south It appears that if the GA meets one of the purposes then it scores of this GA is therefore considered to be flawed relative to this of the M40 (and only the western most tip could be considered as as strongly meeting the Green Belt purpose, despite the fact that statement. adjoining the settlement edge, despite the fact that the GA lies south of the M40) then surely it follows that the M40 is a strong defensible on some purposes the GA scored 0. If the scores are, say 3 for a number of categories, it’s considered to rank as medium. This is not a boundary in NPPF terms and therefore GA 46b ‘plays no role in GA 52a scores 3 and fabrik concur with this scoring. balanced view. preventing the sprawl’ of High Wycombe and therefore also fails The criteria provides a 6 point scoring mechanism for this section (0- Purpose 1 too. 5) again, at odds with the overall scoring system. In connection with the above, Paragraph 5.1.7 also therefore needs Purpose 4: To preserve the setting and special character of to be reconsidered, as do the statistics that follow in this section. historic towns Purpose 2 and 3 Findings: It is considered that the statistics are Neither GA 46b or 52a form the setting to the historic towns identified flawed based on the reassessment of the scoring contained in this in Table 4.3 (p 63). Rightly, both GA score 0 under Table 5.1. document.

The criteria provides a 4 point scoring mechanism for this section In terms of purpose 3, paragraph 5.1.19 sets out that those GA that (0, 1, 3 and 5) and therefore the scoring remains inconsistent with weakly meet this GA have an ‘urban or semi-urban character with paragraph 4.3.3. higher levels of built form, but continue to maintain the openness of some areas of land’. This is not substantiated by any robust fabrik Statement on GBA Site Visits evidence or cross reference to any published Landscape Character Assessment or site landscape assessment work which has informed In relation to paragraph 4.4.15, it appears that only a ‘sense check this overall conclusion. site visit’ was carried out relative to Purpose 1 and 4 Assessments. No reference has been made under whether site visits were carried We concur with the findings relative to Purpose 4 and 5, as these out relative to the other purposes. It is therefore questioned how gaps purposes do not relate to either of the Berkeley sites. were ‘perceived’ relative to Purpose 2; and how rural open / semi- urban and urban character could be defined relative to Purpose 3. Table 5.1: Overall Summary of Findings for Purpose of Assessment (Green Belt General Areas)

Both GA 46b and 52a are deemed to strongly meet the Green Belt purposes according to the assessment. However, there is no

7 A3 ! 9a 17 16a 16c 16b 18b 19 Legend 14a ! 9h 18a ° 9c RSA-5 21a Amersham ! Non-Greenbelt settlement Great ! 22b Walter's 23a Ash Kingshill 22a RSA-7 ! 9f ! 14b RSA-8 Buckinghamshire County 9g 25b Holmer 27 Little Green 24b RGA-5 Chalfont 20 Naphill 21b ! ! RSA-10 District Boundary ! 23b RGA-4 28 Widmer ! 24a Stokenchurch 34 End 24a 33b ! 33e Chorleywood General Areas 26 RSA-9 29 25c Hazlemere ! ! 25a 33a Green Belt Areas for Consideration in Downley 112 32a 36 Landscape Representations Land at Bourne End and Flackwell Heath ! Tylers Stage 2 Green ! 38b 33c RSA-11 Chalfont Areas Not for Consideration in Stage 2 37 High 33d St Giles Wycombe ! RSA-12 ! Maple 39 38a Cross Knotty 32b ! 43a Green ! Seer 38a 114 41b 3. Landscape Critique of Buckinghamshire Green Belt Assessment Lane End 42 Green ! ! RSA-14 113 Beaconsfield 43b 45 ! 41a Chalfont St Peter 44b A3 49a Loudwater RSA-16 ! 46b ! RSA-17 ! Harefield ! 9a Flackwell 48 RSA-15 17 43c 16a 16c 16b RSA-18 RGA-6 40b Section 6 Recommendations 18b Heath Legend Legend 19 49b 47b ! 14a 53a 53b 51 ! 9h 18a 46a 57b 44a ° 9c 55 South RSA-5 ! Amersham Harefield 21a Marlow 52a22b Wooburn 54 ! Non-Greenbelt settlement! Paragraph 6.1.2, sub para 3, sets out that: “Medium or strongly Walter's Great ! Berkeley site locations Bottom23a Green Gerrards RSA-13 Ash Kingshill ! 22a RSA-7 scoring General Areas where there is clear scope for sub-division ! 43e 52b 14b Cross 40a ! 9f RSA-8 ! Denham 9g 50a 43d Wooburn 56 Buckinghamshire County 25b RSA-21 62 Green ! 61 to identify weakly performing ‘sub-areas’ including the presence of Holmer Little! 63 27 64a 24b 60 Bourne ! 111 Chalfont 20 Green RGA-5 RSA-22 boundary features which have the potential to be permanent and Naphill 21b ! End ! RSA-10 59 DistrictRGA-7 Boundary Contains Ordnance Survey data © ! 23b RGA-4 Sub areas28 Crown copyright and database right 2013 Widmer 24a Marlow RSA-19 recognisable; these areas could be afforded further consideration...” Stokenchurch 34 ! 33b ! End 24a 58a 58b 64b 66 ! 26 33e Chorleywood 69 General65b Areas Ickenham RSA-950b 67 29 ! P1 14-11-15 CG ML AB 25c Hazlemere ! ! RSA-20 Farnham Notwithstanding reservations on the scoring of GA 46b and 52a, 25a 33a 68 Green Belt75 Areas for77 Consideration78 in 72 32Cookhama 36 Common Downley 112 New Issue Date By Chkd Appd Tylers ! 71 ! 70 Stage 2 ! whilst these GA have not been identified for inclusion in the ! 76 RSA-23 Denham Green Stoke 38b RSA-27 Poges Recommended Areas, both of these areas include ‘boundary ! 79 33c ! 74 Metres RSA-11 Chalfont RSA-26 Areas Not for ConsiderationUxbridge in Stage 2 37 High features which have the potential to be permanent and recognisable’ 33d St Giles ! 0 1,550 3,100 6,200 Wycombe ! RSA-12 Farnham RSA-24 Iver ! 80b Heath 82 consistent with paragraph 4.3.3 (in terms of motorways) and 4.3.5 Maple Royal RSA-25 38a73 Burnham ! ! 39 Knotty Cross RSA-29 86b High Wycombe 32b ! 81 RGA-8 ! 85a (in terms of unclassified roads and private roads; prominent physical 43a Green ! Seer 38a RSA-28 114 41b 80a 85b 87a features; and existing development with strongly established, regular Lane End 42 Green 83 ! ! RGA-1 86a or consistent boundaries) and which therefore could be considered RSA-14 113 Beaconsfield Maidenhead Iver 43b 45 ! ! 41a Chalfont ! St Peter 44b 88 RSA-30 RGA-2 as scoring weakly. 46b 49a Loudwater RSA-16 Harefield ! RSA-17 ! 13 Fitzroy Street 90RSA-15 ! 43c Flackwell 48 91RGA-6 40b 87b 93 London W1T 4BQ RSA-18 94 West Tel +44 20 7636 1531 Fax +44 20 7580 3924 Heath 47b Slough 95 Drayton GA 46b and 52a warrant inclusion as part of the sieving exercise ! 49b 53b 98 ! 96 www.arup.com 46a 53a 57b 51 ! 55 44a South ! 97 ! Harefield Richings Client of sub areas, especially considering elements such as unclassified Eton 99 Marlow 52a Wooburn 54 ! RSA-31 Wick Park roads, ridgelines, relationships with existing settlement edges Bottom Green Gerrards RSA-13! The Buckinghamshire Authorities ! 43e 52b Cross 40a ! 100 Denham and vegetation providing strong visual enclosure from the wider 50a 43d Wooburn 56 62 Green ! RSA-21 ! 63 61 64a landscape and GA. 60 Bourne ! 111 Colnbrook/ 59 RGA-7 RSA-22 Contains Ordnance Survey data © End Poyle Job Title Marlow RSA-19 Windsor Crown copyright and database! right 2013 Marlow! ! 58b Buckinghamshire Green Belt Assessment Of the 157 GA only 7 areas have been considered to warrant sub 58a 69 64b 65b 66 Ickenham 50b 67 ! P1 14-11-15 CG ML AB division within the Wycombe District Council (WDC) administrative RSA-20 Farnham 68 75 77 78 72 Cookham Common area. These include GA 9a; 9g; 43b; 24a; 58a; 60 and 67. It is New Issue Date By Chkd Appd ! 71 ! 76 70 ! Stoke RSA-23 Denham RSA-27 Poges surprising to note that other GA such as 46b and 52a have identified 79 ! 74 Metres no areas worthy of consideration. A extract of Map 6.1b is shown RSA-26 Uxbridge Map 6.1b Areas for Further Iver ! 0 1,550 3,100 6,200 Consideration at Stage 2, 80b Farnham RSA-24 opposite illustrating the location of the Berkeley sites relative to the Royal Heath 82 South 73 RSA-25 Burnham ! RSA-29 ! 86b sub areas. Having reviewed the characteristics of areas adjoining the ! 81 RGA-8 85a RSA-28 existing settlement edges, it is considered that this sifting exercise is 80a 85b 87a Scale at A3 83 flawed and that GA46b and 52a does in fact have sub areas worthy of 86a 1:115,000 Maidenhead RGA-1 Iver consideration. ! ! Job No Drawing Status 88 RSA-30 RGA-2 242368-00 Issue 90 13 Fitzroy Street 91 87b 93 London W1T 4BQ 94 West Drawing No Issue Slough 95 Tel +44 20 7636 1531 Fax +44 20 7580 3924 Of those sites recommended for consideration in the Part 2 96 Drayton www.arup.com 98 ! ! 6.1b P1 assessment, the following sites were considered by fabrik, during ! 97 Richings Client Eton 99 RSA-31 Park the desk top review stage, to have either similar landscape MXD Location Wick ! The Buckinghamshire Authorities © Arup characteristics to the Berkeley sites or were located around the same 100 settlement and therefore warranted a further review through site Figure 3.2 – Extract from Buckinghamshire GBA showing Map 6.1b showing the sub areas in the Colnbrook/ assessment. Poyle Windsor Job Title southern part of the county (Arup, March 2016) ! ! Buckinghamshire Green Belt Assessment

Map 6.1b Areas for Further Consideration at Stage 2, 8 South

Scale at A3 1:115,000

Job No Drawing Status 242368-00 Issue

Drawing No Issue 6.1b P1

3. Landscape Critique of Buckinghamshire Green Belt Assessment

GA9a, sub area RSA 4 - south of Princes Risborough. The statement at para 6.4.44 that they have: “... little linkage to the wider countryside, and have a more semi-urban character, in GA 9a is assessed as strongly meeting the NPPF purposes. The contrast to the remainder of the parcel” does not represent what broadly rectangular area of RSA 4, through the desk study, looks to is apparent and understood following a field survey. RSA 19 is provide a logical extension consistent with the surrounding settlement certainly influenced by both the commercial and residential buildings pattern. Paragraph 6.4.10 states that: “A very small identified area on the western edge of Bourne End, but does perform a role in in the north of the parcel, RSA-4, is effectively ‘enclosed’ within separating the defined built edge of Bourne End with the ribbon the built-up area of Princes Risborough and its linkage to the development along Hedsor Road; Hawkes Hill; and Kiln End. The wider countryside is weakened as a result of Upper Icknield Way, ribbon development is predominantly set on rising ground against a which binds the area to the south; while this is an un-made road, backdrop of trees. Reservations are raised therefore about the whole it still physically severs the link between this area of land and the of this area being suitable for Green Belt release. countryside beyond and could therefore check the outwards spread of the Princes Risborough / Monks Risborough large built-up area, GA 60 and 67, sub area RSA 21 - West of Bourne End / Wooburn thus diminishing the role of the Green Belt here in preventing sprawl (Purpose 1). This area makes no contribution to the separation Similar to GA 46b and 52a, this area is identified as strongly between settlements... and would, if considered separately from the meeting the Green Belt purposes, however, the identified sub- wider General Area, make a lesser contribution to Purpose 3 as a area is considered an area that “...may meet the purposes weakly result of its sense of envelopment within the built-form of Princes if considered separately.” fabrik concur with this conclusion and Risborough (though the visual link with the countryside to the south recommendation. as a result of the steeply sloping topography should be noted in any further consideration of this area).” fabrik conclusion to GBA

The inclusion of the rectangular area of land is wholly There are a number of inconsistencies with the GBA and importantly misrepresenting the extent of land available for development taking it is considered that there are a number of further sub-areas within the into account topography and the physical and visual relationship GA which warrant further consideration that have not been included in of the central and southern part of this land parcel with the wider the recommendations of the GBA. countryside to the south. The Upper Icknield Way, does not ‘wholly and significantly sever the link between the land and the countryside beyond’, there is a clear visual relationship between the site and the wider landscape in views from within and towards this sub area.

GA 24a, sub area RSA 9 - South of Hazlemere / Holmer Green

The western land parcel of this area only lies within WDC. fabrik concur with the conclusions of this assessment.

GA 58a, sub area RSA 19 and RSA 20 - South/East of Bourne End / Wooburn

In terms of Purpose 3, this area has the same score as 46b and 52a (for this purpose only).

9 Landscape Representations Land at Bourne End and Flackwell Heath

4. Landscape Critique of Wycombe District Council Green Belt Part 2 Site Assessment

Introduction Wider Sense Check Sites identified inthe Arup GBA lie within the AONB which has its own tests for what is considered appropriate development, this is considered a The Part 2 Assessment has considered 3 categories of sites as Page 12 of the document sets out (under the first para) that:“This further tier of planning restraint. follows: validation exercise... specifically will look at the detailed assessment for each general area to see if there is any scope for further sub- Section 3 Findings of the Part 2 Assessment 1. The sub areas identified in the Part 1 Assessment; division based on smaller land parcels.” The findings of the Part 2 Assessment are based on the assessment 2. Developer promoted sites. The Berkeley sites are identified Paragraph 2 of page 12 sets out that: “... particular attention will be work set out in Appendix 4. as SBE0048 - Land east of Chapman Lane, Bourne End and given to the strategic land parcels which abut the High Wycombe SWC0070 - Land north of Heath Road, Flackwell Heath; and urban area, Princes Risborough, Marlow and Bourne End as these In Table 4, both the Berkeley sites at Bourne End and Flackwell Heath locations from Tier 1 and 2 of the Settlement Hierarchy identifying are assessed as not having exceptional circumstances to justify an 3. Wider sense check sites. these locations as the most sustainable for the district.” It should alteration to the Green Belt boundary. Any site that sits within a GA be noted that in addition to the Berkeley sites, the other developer with a summary score of 3 or above has not been considered overall The following paragraphs set out the key landscape and visual points promotion site that has been put forward in Bourne End (land off to have exceptional circumstances to warrant release from the Green of note in the Part 2 Assessment (and in particular relative to the Northern Heights - SBE0049) lies within GA 52b which in the GBA Belt despite whether the site meets the WDC scoring. It is also noted areas of Berkeley interest). concludes that strongly meets the Green Belt purposes. that not all sites sitting within a GA with summary score of 1 or 2 meet the additional WDC criteria for Green Belt release. Conversely, those The document sets out the scope of the Part 2 Assessment; the There is no explanation in the main body of the assessment how the sites (for example, Land at Oak Tree Road, Marlow - SMA0085 and 0086) that meet all of the WDC criteria, but which lies within a GBA findings of the Part 2 Assessment; and a series of Appendices. Of ‘wider sense check’ sites have come forward and how these have which scores a 3, have not been considered suitable for release particular note to this representation is Appendix 3 - Development been selected. This is not included in the methodology for the Part 2 either. This approach is questioned, as there may be areas not Capacity of Green Belt Residential Sites; and Appendix 4 - Individual assessment which is based on the Arup methodology as set out in the identified by the GBA which warrant further consideration and testing Site Assessments. main report. on how these individual sites meet the Green Belt purposes. Section 2 Scope of Sites Assessed Developer Promoted Sites Whilst this Section sets out that the Arup GBA methodology has been used, there is an inconsistency on how appropriate boundaries Summary and Recommendations of the Part 1 Assessment. This section sets out the number of promoted sites and that these have been defined relative to the Arup methodology. The Arup are: “... smaller parcel areas than those considered in Part 1 of methodology includes durable / permanent features such as At page 5 the document sets out the 4 categories of areas for the Green Belt Assessment. Smaller parcel areas could result in a motorways, public and made roads, railway lines, rivers, streams, consideration. The Berkeley sites fall within a GA that are Category different assessment for Green Belt purposes and for development canals, prominent physical feature (such as ridgelines) protected 3, defined as: “Medium or strongly scoring General Areas where potential... Where the site is considered to perform weakly, it woodland / hedge; existing development with strongly established there is a clear scope for sub-division to identify weakly performing is then taken forward to Part 2 of the assessment to consider regular or consistent boundaries (emphasis added). A number of sites ‘sub-areas’, including the presence of boundary features which have the development potential and whether there are exceptional have been included in the sieving exercise based on non-protected the potential to be permanent and recognisable.” (fabrik emphasis circumstances for the site to be removed from the Green Belt.” vegetated boundaries. added). The Assessment has included promotion sites adjacent to settlement The development capacity of Green Farm, High Wycombe This section then goes on to set out a summary of the findings tiers 1-4 and therefore includes both Bourne End (Tier 2) and (SHW0633) relies on ‘recently planted tree belts’ beyond the site relative to the RSA sites from the GBA within Wycombe DC. Flackwell Heath (Tier 3). boundary as a durable feature despite the fact that these may not be ‘protected’. This approach can therefore be equally applied potentially As highlighted in this representation, 3 of the sub parcel areas to other promotion sites to allow more Green Belt releases.

10 Landscape Representations Land at Bourne End and Flackwell Heath

4. Landscape Critique of Wycombe District Council Green Belt Part 2 Site Assessment

Section 3 Findings of the Part 2 Assessment (continued) as a Major Developed Site in the Green Belt; and the site at Sidney exception of SHW0462) and which conclude that there are no House, Lane End (5) has ‘specific site constraints’ (and may not be ‘exceptional circumstances likely to justify alteration to the Green In terms of the Chapman Lane, Bourne End site (SBE0048) there deliverable). The Berkeley sites are not included in this short list. Belt boundary’. Within the text set out at p 40 there is justification is the opportunity to create new planting belts along the northern for the release of SHW0529 overcoming potential objections for edge of the site to form a new appropriate and permanent Green Belt Sites Identified for Further Consideration at Assessment Stage release. In terms of the Airpark sites, the assessment sets out (p boundary. Notwithstanding this, the ridgeline and vegetation beyond 40) that: “... the suggested new green belt boundary which would the site to the north are significant and robust physical and visual In Appendix 4, the site assessments highlight other reasons for run across open fields with no physical demarcation.”Whilst features which equally could create a new Green Belt boundary. the sites to be considered further (with the exception of Clay Lane, there may be aviation licensing constraints to development, these Furthermore, the land to the north and north-east is designated as Booker - SWH0559). There is an inconsistency of approach to constraints are not consistent with the boundaries identified in the a Local Landscape Area adding a further tier of planning restraint. considering these sites. Arup methodology as used by WDC. Site SHW0559 - land at Clay It is considered, therefore, that sites outside of any landscape Lane is recommended to remain in the Green Belt principally due designations should be ranked higher than those within a designated All of these sites have been considered in Table 4 and deemed that to the lack of strength and permanence to the existing boundaries landscape. there were no exceptional circumstances to justify release from the (and without the aviation licencing constraint). The overall Green Belt. conclusion is that 5 of the 6 sites should be released from the In terms of the approach to the contribution that the sites can make to Green Belt, of which 3 are promoted for residential. meeting housing or other needs (i.e. whether it is deliverable) in our In particular, the following should be noted: opinion is not consistent. It is not clear how the different scoring of the 4. Land at and adjoining Culverton Farm, Princes Risborough Northern Height site (SBE0049) has been determined (i.e. if the GA 1. Land off Penn Road, Hazelmere (SHZ0030) sits within a GA (SPR0036, SPR0082, SPR0085 and SPR0088). This has been is a score of 2 and meets the other WDC criteria, then it automatically which scores 3 and whilst meeting all the WDC criteria, has not included in the assessment relative to strategic traffic routes as is deliverable). Potentially both the Chapman Lane site (SBE0048) been identified for Green Belt release and therefore has been part of the Town Plan (AAP). Whilst the individual site assessment and Hollands Farm (west - SBE0053) are both deliverable as they are discounted. This site lies within the AONB. This remains a site to does not support the release of these sites, they have been sites being promoted by developers. It is interesting to note that the be: “...considered further following public consultation on the draft included as development may be deemed appropriate for Hollands Farm sites (SB0027 and SB0028) are identified as being Local Plan...” (p 37). release in the future and therefore consider worthy of inclusion deliverable. How this has been defined is not set out in the individual in the consultation process. This is a departure from the Arup site assessment sheets in Appendix 4. The consistency of approach 2. Land at Oak Tree Road, Marlow (SMA0085 and SMA0086) again methodology included at Appendix 2. Furthermore, the road is therefore questioned. sits within a GA which scores 3 and whilst meeting all of the WDC proposal is not a consented scheme and is therefore considered a criteria, has not been identified for Green Belt release. This site premature option. There is no consideration in Section 3 of how appropriate boundaries again lies within the AONB and forms both the landscape setting could come forward for the smaller development parcels which could to Marlow and the separation between Marlow and Marlow Conclusions then potentially change whether the site could be released from the Bottom. The assessment identifies that the development of the Green Belt. site may have a landscape impact. Notwithstanding these issues, Wycombe District Council have identified a“handful of sites which this remains a site to be “considered further following public could be removed from the Green Belt”. Sites Identified for Release at Assessment Stage consultation on the draft Local Plan.” (p 38). These sites are generally small sites. Of the 62 sites considered (including sub areas, developer promoted 3. Booker Airpark and High Heavens (comprising 6 individual sites sites and wider sense check sites) only 9 sites have been identified including Airpark 1, 2 and High Heavens and including SHW0462, that have exceptional circumstances for Green Belt release. This SHW0529 and SHW0559). The Airpark and High Heavens section then lists the sites and gives a new reference number. sites are considered for employment and the remaining sites for Although of the 9, the RAF Walters Ash site (8) is already defined residential. The scores for these individual sites vary (with the

11 Landscape Representations Land at Bourne End and Flackwell Heath

4. Landscape Critique of Wycombe District Council Green Belt Part 2 Site Assessment

Appendix 3 Site Assessments - Development Capacity of Green landscape character; settlement pattern; recreation and culture; reducing development potential. However, overall, there is an Belt Residential Sites skyline / panorama / landmarks; strengths and sensitivities; inconsistent approach to statements on the likely harm to those development capacity. These factors all influence the potential sites in the AONB. This Appendix sets out the development capacity of the sites development of the site. assessed, although does not include those sites that have specific 11. There is an inconsistent approach to whether sites are included site constraints (specifically RAF Walters Ash - Site 8 and Sidney 4. Whilst the assessment sets out which Landscape Character Area based on development on three sides of the site, for example, House, Lane End - Site 5) but also does not include the Northern covers the site, there is no further information which sets out the Clappings Lane (SNH0019) has residential development on Heights, Bourne End - Site 9. key character issues and guidelines and is therefore meaningless three sides and is included as one of the proposed sites to be as a subsection. released from the Green Belt, however both Chapman Lane Page 2 of the document sets out that the assessments included a (SBE0048) and Heath End Road (SWC0070) have development detailed summary of the site constraints. It is therefore questioned 5. The assessment inconsistently identifies where allotments abut predominantly on three sides (albeit for Heath End Road why these sites have not been included as part of the assessment. sites. Whilst it is understood that these are considered to have beyond woodland on one side and not necessarily continuous ‘little permanence’, they are also recognised to be ‘enduring’. As development) the latter two sites not being included as part of the Appendix 4 such, there is an inconsistent approach to the methodology. proposed releases.

This section sets out a more detailed individual site assessment of all 6. There is an inconsistency about the sense of enclosure afforded 12. The Airpark site has no physical boundaries to demark the the sites identified in Table 2 and the justification for being suitable to each of the sites, albeit it that enclosure may be provided by suggested new boundaries of the Green Belt. Whilst it is for Green Belt release. range of factors, be it topography, vegetation or built form. understood that aviation licensing constrains future development and therefore can provide a degree of permanence, this Of those sites identified to be released from the Green Belt, the 7. There is an inconsistent assessment of neighbouring uses. Some permanence is only relative to the operation of the airfield. As follows points are material: assessments consider that neighbouring residential development such, there is a lack of consistent approach to the identification of forms part of its ‘strong defensible boundaries’ and a ‘strong boundaries relative to following the Arup methodology. 1. There is an inconsistent approach to the site selection urbanising influence’, whereas for other sites (such as Chapman methodology, for example GA 52b whilst being on the edge of a Lane) this is not recognised at all despite its clear presence and In addition to the above, the following issues identified in Appendix large built up area (unlike GA 52a) and therefore passes this test, influence over the site. 4 are of particular note relative to the Chapman Lane, Bourne End has a score of 3+ relative to preventing the outward sprawl of (SBE0048) and Heath End Road, Flackwell Heath (SWC0070) sites. large built up areas (unlike GA52a which has a score of 0). The 8. Sites with intervisibility to Registered Parks and Gardens have Northern Heights (SBE0049) site has therefore been included in not been excluded from the assessment and remain as sites Land at Chapman Lane, Bourne End (SBE0048) the sieve relative to lying on the edge of a large built up area, but considered to have potential for development. in fact this site does not lie on the edge of Wycombe but on the Similar to the Northern Heights (SBE0049) site, the Chapman Lane edge of Bourne End. 9. There is an inconsistent approach to defining boundaries site: that have permanence. The assessment includes vegetated 2. The level of information included is inconsistent. For example, boundaries whether protected or not. 1. in the GBA lies within a GA identified as strongly meeting the information on the Conservation Area, Listed Buildings / HPG Green Belt purposes; (Historic Parks and Gardens) and TPO’s has not always been 10. Sites that lie within the AONB and Local Landscape Areas are included, despite one of the sites backing on to a Conservation included on the list of sites to be released over and above those 2. adjoins non-Green Belt land and therefore removal of this site Area and with Listed Buildings present beyond the site boundary. that lie outside of these designations, however it is noted that the would similarly result in it being contiguous to the non-Green Belt assessment states that these may be subject to further scrutiny area of Bourne End; 3. There is an inconsistency to reporting on the following aspects: following further consideration of landscape and visual issues,

12 Landscape Representations Land at Bourne End and Flackwell Heath

4. Landscape Critique of Wycombe District Council Green Belt Part 2 Site Assessment

Land at Chapman Lane, Bourne End (SBE0048) continued flanking most of the eastern edge of the site. This is at odds with the assessment of the Northern Heights and the Chapman Lane sites assessment of the Northern Heights Site which identifies that the in terms of consideration of existing built form influences, settlement 3. has a gradual upward slope from south to north (although not site is on the edge of the built up area and despite being flanked by pattern and landscape mitigation. recognised in the WDC site assessment, but then later on in the detached dwellings in well vegetated framework and which is defined landscape appraisal section recognises that it is sloping. As such as that which has a mixed urban-rural character. The approach to Heath Road, Flackwell Heath (SWC0070) there is an inconsistency to the approach); the assessment of the urban influences to the sites is therefore not consistent. The score of the Chapman Lane site ‘relatively strongly’ A wider area has been included as part of the assessment of sites in 4. the site lies outside of the AONB; meeting the NPPF purposes is therefore questioned relative to how Appendix 4 and includes all of the land between Heath End Road and the Northern Heights site is assessed. the M40. This is larger than the area of land promoted by Berkeley. 5. is in agricultural use with adjoining housing and treebelts; It is acknowledged there is no physical definition of a boundary to The assessment fails to recognise the built form context provided by 6. there are no public rights of way that cross the site; the north-eastern edge of the site for a short section. However, this Amersham College to the west of the site. is marked in planning terms by the boundary of the LLA. Therefore 7. views inwards would occur from neighbouring residential the sweeping statement included in Appendix 4 that: “... as a whole, The site assessment relative to the Green Belt fails to: properties and long distance from the south; the site does not have a strong defensible boundary.” The northern boundaries by vegetation and property boundaries; the eastern 1. recognise that part of the larger area includes an area of open 8. views outwards are long distance to the south; and and southern boundaries are defined predominantly by built form or space to the north of the woodland; the LLA; the south-western boundary by the allotments; and west 9. there are no skyline, panoramas or landmark features (these are edge by Chapmans Lane and the individual dwellings beyond. The 2. assess how much of the site forms part of a gap between formed by the treebelts beyond the site). assessment therefore has not considered these key physical factors Flackwell Heath and High Wycombe considering the existing in a consistent manner. development to the east of the site and the existing intervisibility In addition, the site lies wholly outside of the LLA (although the between the two settlement areas; assessment sets out that the site lies adjacent to the Western Wye Similar to the Northern Heights site, adjacent dwellings to the Valley LLA). There are no TPO’s within the site. Chapman Lane site are likely to be sensitive to the visual impact of 3. recognise the topography of the site, including a ridgeline and new development; and that development would be complementary high point in the centre of the site (stating that the site is ‘relatively The assessment of how the site area meets the NPPF purposes, with the adjoining land uses. flat’). This is incorrect. Appendix 4 of the Part 2 study sets out that the: “site encroached into an essential gap between non-green belt settlements (Bourne Whilst landscape mitigation measures (in the way of extensive tree In addition, the landscape assessment section fails to: End and Flackwell Heath).” There is no perception of Flackwell planting, especially in the northern portion of the site and adjoining Heath from within the site due to the combination of topography and neighbouring properties) have been identified for the Northern 5. recognise the urbanising influences of Amersham College and vegetation which predominantly masks views of Flackwell Heath Heights site, there is recognition that ‘with appropriate mitigation’ associated uses to the west. from within the site. Notwithstanding that fact the southern edge of there is potential for the site at Chapman Lane to accommodate Flackwell Heath and northern edge of Bourne End are conjoined development. However, unlike the Northern Heights site, there are no fabrik conclusion on WDC Part 2 Assessment along Blind Lane to the east of the Bourne End site through ribbon recommendations on what this could be. development, the site does not provide part of an ‘essential gap’. The There is an inconsistent approach to the assessment of the individual scoring of this element is therefore questioned. There is no robust justification or evidence on why the capacity for sites, the findings of which are therefore challenged. development on this site is assessed as being low. There is no recognition in the site assessment of the Green Belt in NPPF terms that there is a line of residential development Overall, there is an inconsistency of approach between the

13 Landscape Representations Land at Bourne End and Flackwell Heath

5. Landscape Analysis and Landscape Development Parameters Legend Site Promotion Area

5.1 Landscape Analysis of Land at Chapman Lane, Bourne End (SBE0048) Area of Outstanding Natural Beauty (AONB)

Considering the inconsistencies of approach to the Stage 2 report, Local Landscape Area and if applying the same assessment approach, it is considered that (LLA) the Land at Chapman Lane should be further considered for Green Belt release. Chapmans Lane1 Minor valley

The plan opposite illustrates the inherent landscape and visual issues associated with the above site in consideration of the landscape and 2 Direction of slope visual issues considered in the alternative sites.

The site lies on south facing slopes, consistent with the existing 1 Existing significant developed edges of Bourne End and is currently in arable use. vegetation Settlement areas The site has strong urban / sub urban edge influences to the south and east informed through a combination of built form associated with 2 residential, commercial / utility and educational uses and therefore Dwellings providing is varied in scale and mass. The site is therefore not free from the urban influence influences of neighbouring development. It is therefore considered an over generalisation in the Stage 2 report that the site ‘feels largely 3 Individual dwellings / rural in character’. Residential uses along the western edges of the buildings in well treed site are apparent along Chapman Lane, but due to the intervening 4 setting vegetation are less apparent from within the site. Wessex Water sites including built form The majority of the site boundaries are robust in NPPF terms (and 5 applying the same principles as WDC as used on other sites) as they School and are either defined by landscape designations; existing built form; associated grounds allotments; road corridors; and vegetation. Furthermore, there are 6 Green Space measures that can be taken to ensure a future robust boundary is created in the long term (consistent with the approach to the Northern Goddington Road Heights site) and hence the site is considered suitable for release Allotments from the Green Belt. Blind Lane

Wendover Road Single dwellings with 1 southern aspect

Unity House set in 2 Figure 5.1 – Extract from Ordnance Survey Plan showing landscape analysis of Chapman Lane site well treed setting (fabrik, 2016) Viewpoints (see 1 following page)

14 Landscape Representations Land at Bourne End and Flackwell Heath

5. Landscape Analysis and Landscape Development Parameters

Photograph Survey

Photograph – Viewpoint 1 Photograph – Viewpoint 2 View looking south east across the site from the north-western corner. The existing developed edges of Bourne End (predominantly 2 storey) View looking south-east towards the site from Chapman Lane providing an urbanising element to the view. adjacent to the Wessex Water reservoir. Views of the site are wholly obscured by the intervening vegetation.

Photograph – Viewpoint 3 View looking east across the site from field entrance gate to the north of the allotments. The existing residential edge on the eastern edge of the site provides an urbanising element to the view. There is no perception of Flackwell Heath due to the intervening layers of vegetation.

15 Landscape Representations Land at Bourne End and Flackwell Heath

5. Landscape Analysis and Landscape Development Parameters

Photograph Survey

Photograph – Viewpoint 4 Photograph – Viewpoint 5 View looking east towards the site over the intervening allotments. View looking west towards the site from Goddington Road. Views of the site are wholly obscured by the intervening dwellings.

Photograph – Viewpoint 6 View looking north towards the site from Wendover Road. Views of the site occur in the context of the existing developed edges of Bourne End (predominantly 2 storey).

16 Landscape Representations Land at Bourne End and Flackwell Heath

5. Landscape Analysis and Landscape Development Parameters

5.2 Landscape Development Parameters Legend

The development parameters applied in Appendix 3 of Part 2 of the Site Promotion Area Green Belt study have been applied to the site as illustrated opposite, which shows the potential development capacity of the site in landscape and visual terms considering: Proposed residential

1. The northern boundary of the proposed development parcel could be defined through advanced planting (as part of the proposed Proposed open space development) to provide a new Green Belt boundary and to set 1 the proposed development in to a landscape structure consistent with the characteristic pattern of treebelts along the northern edge Proposed green of Bourne End. corridor 2. The inclusion of a green corridor along the western edge of the development to maintain the green lane character of Chapman Proposed treebelts Lane and in consideration of the character of residential development to the west of Chapman Lane. Existing vegetation 3. The continuation of the green space beyond the site to the south providing landscape into the southern section of the site in an area well related to the setting to the site allotments. Sensitive existing 4. The retention of the land parcel to the north as agricultural land residential boundary and therefore the development of the site as illustrated opposite would not result in a reduction of the actual or perceived gap Potential vehicular between Bourne End and Flackwell Heath; and would deliver access (to be a logical urban extension, not extending the visual envelope reviewed by highways associated with Bourne End. Blind Lane engineer) Chapmans Lane

5. In relation to para 4.4.8 of the GBA (Arup report) relative to the Retention of agricultural 1 definition of sprawl (the outward spread of a large built up area field parcel at its periphery in an untidy or irregular way) the development as illustrated opposite would not represent sprawl, as it would not Goddington Road extend beyond the existing developed envelope of the settlement, especially considering the neighbouring residential land to the east.

6. The existing treebelts beyond the site to the north forming the Figure 5.2 – Extract from aerial showing landscape development parameters of Chapman Lane site landscape setting to Bourne End. (fabrik, 2016)

17 Landscape Representations Land at Bourne End and Flackwell Heath

5. Landscape Analysis and Landscape Development Parameters

5.3 Meeting the Green Belt Purposes

The proposed development parameters illustrated on the previous page addresses the purposes of the Green Belt as follows in landscape and visual terms:

Purpose 1 - To check the unrestricted sprawl of large built up areas: The site does not lie adjacent to a ‘large built up area’. Therefore this purpose is not applicable.

Purpose 2 - To prevent neighbouring towns merging into one another: The site lies between two residential areas, with residential uses extending to the north-east beyond the site. The site does not provide an ‘essential gap’ between the settlements of Bourne End and Flackwell Heath (which in any event are conjoined by ribbon development along Blind Lane). There is currently visual and physical separation between the site and Flackwell Heath provided by the combination of the upper valley slopes and series of intervening treebelts. The site sits below the well treed skyline and the upper valley slopes.

Purpose 3 - To assist in safeguarding the countryside from encroachment: Whilst the site is countryside, the proposed development parcels continue the pattern and grain of development present to the east of the site. As with the development of any green field site currently in the Green Belt, this purpose can not be fully addressed, however, it is to be noted that this site is an area that is already clearly influenced by the existing mixed developed edges of Bourne End and is therefore not free from development influences. The wider effects can be minimised through the consideration of the measures set out in this document.

Purpose 4 - To preserve the setting and special character of historic towns: The site does not lie adjacent to a historic town and is therefore not applicable to this site.

Purpose 5 - To assist in urban regeneration, by encouraging the recycling of derelict and other urban land: This purpose is not applicable to this site and is therefore this purpose is discounted.

18 Landscape Representations Land at Bourne End and Flackwell Heath

5. Landscape Analysis and Landscape Development Parameters

5.4 Landscape Analysis of Land at Heath End Road, Flackwell Legend Heath (SWC0070) Site Promotion Area Considering the inconsistencies of approach to the Stage 2 report, it is considered that the Land at Heath End Road should also be further M40 Area of Outstanding considered for Green Belt release. Natural Beauty (AONB)

The site lies to the south of a local ridgeline and on south facing Local Landscape Area slopes, consistent with the existing developed edge of Flackwell (LLA)

Heath both to the east and west of the site. The site is currently used Spring Lane as paddocks and therefore has a typical urban fringe character. The 1 Local minor ridge land to the north is in arable use. Direction of slope The site lies between the existing developed edges associated with 8 Flackwell Heath. Amersham College is identified in planning terms as a Major Developed Site in the Green Belt. This site, together with its Existing significant associated grounds (which include floodlighting) and neighbouring vegetation uses together form the western edge of Flackwell Heath. Amersham 2 College is clearly visible passing Spring Lane on Heath End Road, Settlement areas especially travelling west. The site includes Heath End Farm and associated buildings. 3 Dwellings providing The southern edge of the site is influenced by the adjacent residential 4 urban influence uses to the south of Heath End Road. There are a series of 5 Amersham College and defensible boundaries present, the ridgeline and M40 to the north; the 6 associated grounds woodland to the east; Heath End Road to the south; and Spring Lane to the west. The ribbon of residential development to the south of the 7 Area of public open site influences the southern edge of the site. The presence of Heath Heath End Road space End Farm is apparent when travelling south along Spring Lane. Approximate location of The northern edge of Flackwell Heath extends up to the M40 road speed restriction sign corridor and is separated from High Wycombe through intervening woodland. Development on this edge comprises of 2 and 3 storey Viewpoints (see 1 buildings. following page)

The western edge of Flackwell Heath is defined by the speed restriction sign and traffic island. The road at this point is flanked by trees creating a green corridor. Dwellings become apparent on approaching Spring Lane and once at Spring Lane there is a sense of Figure 5.3 – Extract from Ordnance Survey Plan showing landscape analysis of Heath Road site (fabrik, arriving on the fringes of Flackwell Heath. 2016)

19 Landscape Representations Land at Bourne End and Flackwell Heath

5. Landscape Analysis and Landscape Development Parameters

Photograph Survey

Photograph – Viewpoint 1 View looking south-east towards the site from Spring Lane. Glimpsed views of the northern edge of the site (where it lies to the south of the ridgeline apex) occur filtered through the intervening vegetation. There is no perception of Flackwell Heath at this point of the road corridor.

Photograph – Viewpoint 2 Photograph – Viewpoint 3 View looking across the site from the entrance to Heath End Farm off Spring Lane. Open views of the site occur in the context of the well treed Filtered and glimpsed view looking east across the western field backdrop. parcel of the site from Spring Lane between the roadside vegetation. Wider views of the site are limited by the intervening layers of vegetation.

20 Landscape Representations Land at Bourne End and Flackwell Heath

5. Landscape Analysis and Landscape Development Parameters

Photograph Survey

Photograph – Viewpoint 4 Photograph – Viewpoint 5 View looking north-west towards the campus of Amersham College from the southern edge of Spring Lane. Views of the site are limited from View looking east along Heath End Road adjacent to the speed this location due to the intervening layers of vegetation. The flood lights of the wider grounds are evident in the distance. restriction sign. The built form of Flackwell Heath is obscured by the intervening vegetation.

Photograph – Viewpoint 6 View looking north-east towards the site emerging from the footpath to the south of Heath End Road. Views of the site are wholly obscured by the intervening vegetation.

21 Landscape Representations Land at Bourne End and Flackwell Heath

5. Landscape Analysis and Landscape Development Parameters

Photograph Survey

Photograph – Viewpoint 7 View looking north towards the site from Heath End Road. Views of the site occur in the context of the existing residential development both to the south and north of the Heath End Road.

Photograph – Viewpoint 8 Photograph – Viewpoint 8 a View looking south-west towards the site from the public open space to the north-west. The edge of the View looking north-east across the public open space to the north- site is not perceived from this location. The opposite view away from the site is influenced by two and three west. Views from the public open space are influenced by the existing storey dwellings - see viewpoint 8a. urban edge of Flackwell Heath.

22 Landscape Representations Land at Bourne End and Flackwell Heath

5. Landscape Analysis and Landscape Development Parameters

5.5 Landscape Development Parameters Legend

The development parameters applied in Appendix 3 of Part 2 of the Site Promotion Area Green Belt study can be applied to the site as illustrated opposite.

The plan shows the potential development capacity of the site in Proposed residential landscape and visual terms considering the following:

1. The boundary to the north of the site could be defined through Proposed open space advanced planting (as part of the proposed development) along the northern edge of the site, to provide a new Green Belt boundary and to set the proposed development in to a landscape Proposed 15m buffer structure consistent with the pattern of treebelts locally. to Ancient Woodland 2. The inclusion of a network of open spaces that protect the higher ground and maintains the landscape setting and approach to Proposed treebelts Heath End Farm buildings.

3. The inclusion of 15m wide green buffers to the Ancient Woodland. Existing vegetation providing landscape 4. The development of the site as illustrated opposite, set on south setting to the site facing slopes, would not result in a reduction of the actual or perceived gap between Flackwell Heath and High Wycombe; and Sensitive existing would result in the rounding off of the settlement, not extending residential boundary the existing visual envelope associated with Flackwell Heath. Potential vehicular 5. In relation to para 4.4.8 of the GBA (Arup report) the assessments access points (to be definition of sprawl is the outward spread of a large built up area reviewed by highways at its periphery in an untidy or irregular way. The development of engineer) the site, in consideration of the Major Developed Site in the Green Belt and the northern most extremity of Flackwell Heath to the Existing open space north against the M40 corridor, would also not represent sprawl based on the above definition.

Figure 5.4 – Extract from aerial photo showing landscape development parameters of Heath End Road site (fabrik, 2016)

23 Landscape Representations Land at Bourne End and Flackwell Heath

5. Landscape Analysis and Landscape Development Parameters

5.6 Meeting the Green Belt Purposes

The proposed development parameters illustrated on the previous page addresses the purposes of the Green Belt as follows in landscape and visual terms:

Purpose 1 - To check the unrestricted sprawl of large built up areas: The site does not lie adjacent to a ‘large built up area’. Therefore this purpose is not applicable.

Purpose 2 - To prevent neighbouring towns merging into one another: The site is influenced predominantly to the south and west by both residential and educational buildings and to a lesser extent to the north-east. There is currently intervisibility between the northern edge of Flackwell Heath and High Wycombe. On Spring Lane, there is no perception of Flackwell Heath due to the intervening local minor ridgeline present to the north of the site. The combination of the M40 corridor and this ridgeline serves as a robust boundary between high Wycombe and the site. The site therefore does not provide an ‘essential gap’ between these two settlements.

Purpose 3 - To assist in safeguarding the countryside from encroachment: Whilst the site is countryside, the key characteristic elements of vegetated field boundaries and the setting to Heath End Farm can be retained. The proposed development parcels are set back significantly from the skyline ridge present beyond the site to prevent encroachment into the wider countryside. As with the development of any green field site current in the Green Belt, this purpose can not be fully addressed, however the wider effects can be minimised through the consideration of the measures set out in this document.

Purpose 4 - To preserve the setting and special character of historic towns: The site does not lie adjacent to a historic town and is therefore not applicable to this site.

Purpose 5 - To assist in urban regeneration, by encouraging the recycling of derelict and other urban land: This purpose is not applicable to this site and is therefore this purpose is discounted.

24 Landscape Representations Land at Bourne End and Flackwell Heath

5. Conclusions

There are a number of inconsistencies in the approach within the Buckinghamshire Green Belt Assessment and it is considered that a number of additional sub-areas within the General Areas which warrant further consideration that have not been included in this assessment.

In terms of the Wycombe District Council Draft Green Belt Part 2 Assessment, there is an inconsistent approach to the assessment of the individual sites. The identification of sites proposed for Green Belt release is therefore challenged.

There are a number of similarities to be drawn between the proposed Green Belt releases and the Berkeley sites. This document has set out a detailed site analysis of the sites together with a landscape led development parameters plan that sets out how these sites could be released from the Green Belt.

An objective landscape analysis of the Bourne End and Flackwell Heath sites has been carried out and has informed the landscape led development parameters plan. The assessment and plans have been prepared considering the sites inherent landscape sensitivities and how these sites perform under the Green Belt purposes.

It is considered that both Berkeley sites could come forward to deliver development in a manner which maintains the relevant 3 purposes of the Green Belt beyond the site boundaries and therefore could be released from the Green Belt in a consistent way to the other sites proposed by Wycombe District Council.

25 Annex 3 – Heath End Farm Plan Land at Heath End Farm, Flackwell Heath Annex 4 – Land at Chapman Lane, Bourne End Plan Land at Chapman Lane, Bourne End