The Chilterns Conservation Board the Lodge 90 Station Road Chinnor Oxfordshire OX39 4HA
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The Chilterns Conservation Board The Lodge 90 Station Road Chinnor Oxfordshire OX39 4HA Contact: Lucy Murfett, PhD MRTPI, Planning Officer Chairman: Cllr Ian Reay Tel: 01844 355507 Vice Chairman: Helen Tuffs Fax: 01844 355501 Chief Officer: Sue Holden E Mail: [email protected] www.chilternsaonb.org Chilterns AONB in Wycombe District – view from Coombe Hill Photo: Richard Gillin Statement from the Chilterns Conservation Board Wycombe Local Plan Examination 2018 MATTER 9 – DEVELOPMENT FRAMEWORK: RURAL AREAS 2nd August 2018 1 Examination statement from the Chilterns Conservation Board Introduction 1. The Chilterns Conservation Board is grateful for the opportunity to participate at the Wycombe Local Plan examination. 2. The Chilterns Conservation Board (CCB) is a statutory body established in 2004 under the provisions of the Countryside and Rights of Way Act 2000 to promote the conservation and enhancement of the Chilterns Area of Outstanding Natural Beauty (AONB) and increase the understanding and enjoyment by the public of the special qualities of the AONB. Further information about the Board and our role is set out in Appendix 1. 3. An Area of Outstanding Natural Beauty is an outstanding landscape whose distinctive character and natural beauty are so precious that it is in the nation’s interest to safeguard them. The Chilterns AONB was designated in 1965. Its special qualities include the steep chalk escarpment with areas of flower-rich downland, woodlands, commons, tranquil valleys, the network of ancient routes, villages with their brick and flint houses, chalk streams and a rich historic environment of hillforts and chalk figures. 4. Our statement addresses Inspector’s questions 1a, b, d, f, g, h, j and k of matter 9. 5. The Chilterns Conservation Board seeks amendments to modify or delete allocations that affect the Chilterns AONB Q1. Are the following allocations soundly based and is there evidence that the development of the sites is viable and deliverable? The allocations are not sound, because they are not consistent with national policy, for the reasons set out below: 2 a) RUR1 – Land South of Finings Road, Lane End This site is in the Chilterns AONB. The Chilterns Conservation Board objects to the allocation. A housing development of 19 dwellings here will not conserve and enhance the Chilterns AONB. This allocation fails to give great weight to conserving and enhancing the natural beauty of the AONB as required by para 115 of NPPF (now 172). This is attractive undulating rural pasture used for grazing cattle. In a sensitive location between ancient woodland and a Conservation Area and listed building, it is valuable in terms of natural and historic environment as well as having a strong landscape character. Residential development bordering the wood is likely to increase disturbance to the wood, a 15 metre buffer would not safeguard this. There is no defensible boundary to prevent pressure for future development of the rest of the field. Any improvements to the access onto Finings Lane and introduction of footways to the village would affect rural character. The site comprises attractive rural pasture land in the AONB. Lacks a boundary to prevent pressure for future development of the rest of field: 3 Boundary of mature trees and in setting of a Grade II listed building and Conservation Area: Rural access and ancient woodland on eastern boundary of site. Note Bucks County Council comments ‘would have to either improve visibility to meet Manual for Streets guidance, or not result in vehicular intensification’. A housing development would clearly result in vehicular intensification compared with the current use (livestock farming and access to water tower), and transport engineering to improve visibility would be likely to affect rural character by creating alien and urbanising features: 4 There is no pavement to village on this side of road or safe crossing point, adding a footway or crossing would urbanise the village edge: Advice in the Chilterns Environmental Guidelines for the Management of Highways in the Chilterns is that: “Unless there is an overriding safety issue, do as little as possible. 1. Part of the attraction of the Chilterns is the network of ancient lanes and holloways, especially those on steep valley sides and the escarpment. The informality and apparent 'naturalness' of these roads is fundamental to their appeal. Any sort of engineering feature, even white lines, detracts from their 'fit' into the landscape. 2. Whilst one of the objectives of these guidelines is to minimise the intrusiveness of management practices there will always be a need for a basic level of maintenance. However, even the impact of small works should not be underestimated and minimal intervention is generally more appropriate. 3. The special rural character of a section of road can often depend upon small features, and changes to these can greatly alter perceptions of the area. The cumulative effect of these small works should be recognised. This may require a longer term view as each successive period of work may be several years apart. Examples include the installation of kerbs, the replacement of a hedge with wire fencing, the use of concrete rather than timber posts and the erection of street lights. 4. Where possible, ensure that the road belongs in the landscape rather than imposes upon it.” 5 This site has an access problem. The land required for the access is Registered Common Land, part of Boulter End Common. Any new access across the common would require the completion of a separate legal process under Section 38 of the Commons Act 2006. This requires common land consent for restricted works from the Planning Inspectorate on behalf of the Secretary of State for Environment, Food and Rural Affairs. Details on the process here https://www.gov.uk/guidance/carrying-out-works-on-common-land. Applications are determined against criteria set out in Section 39 of the Act including nature conservation and the conservation of the landscape. There is no certainty that consent would be forthcoming. Recommended changes RUR1: Delete allocation 6 b) RUR2 – Land between Chalky Field and Marlow Road, Lane End This site is in the Chilterns AONB. The Chilterns Conservation Board objects to the allocation. A housing development here of 27 dwellings will not conserve and enhance the Chilterns AONB. This allocation fails to give great weight to conserving and enhancing the natural beauty of the AONB as required by para 115 of NPPF (now 172). Development would neither conserve nor enhance this attractive gently sloping pastureland in use for sheep grazing. It would represent urban encroachment beyond the south eastern edge of Lane End. The lack of a defensible boundary could lead to pressure in time to develop whole field to Lower Court Farm. Attractive grazed pastureland in AONB with undulating valley: 7 Lack of defensible boundary could lead to pressure for future westwards expansion: Recommended changes RUR2: Delete allocation 8 d) RUR4 – Little Marlow Lakes Country Park The supporting text explains at para 5.5.25 the requirement to reflect the open nature of the site and the views from the AONB, as well respecting and enhancing the Conservation Areas and enhancing biodiversity. There are panoramic views over the lakes from Winter Hill in the AONB. For consistency with the lower case text and effectiveness of the policy, the AONB should also be referred to in policy; it would slot well into bullet point 4. Recommended changes RUR4: Amend text to: “4. Planning permission will not be granted for development within the country park that that has an adverse effect upon the amenities or setting of the River Thames, watercourses, lakes, wet woodlands, the adjacent AONB, adjoining conservation areas or Listed Buildings, or which prejudices the function of the area for the purposes of a country park.” f) RUR6 Great and Little Kimble-Cum-Marsh Parish Great and Little Kimble cum Marsh Parish is partly in the Chilterns AONB and firmly in the setting of the AONB. This is a highly sensitive area, with magnificent close views to and from some of the most beautiful parts of the Chilterns chalk escarpment. It is visible from Beacon Hill and Coombe Hill, among the most visited and popular viewpoints in the AONB (please see photo showing the iconic Beacon Hill and Kimble beyond on the front cover of this Statement). This is a rich historic environment, an ancient landscape with a remarkable concentration of historical sites: an iron age hillfort, a Roman villa, a Norman motte and bailey castle, and in the 19th Century a lace-making school of importance to the Buckinghamshire lacemaking industry. In close proximity is rare box woodland at Great Kimble Warren and Ellesborough, which is the largest area of native box woodland in the country, designated as of international importance as a Special Area of Conservation, as well as a cluster of sites of local and national importance (SSSIs, Local Wildlife Sites, Ancient Woodlands and a Biodiversity Opportunity Area – see map overleaf). This is a parish of small villages and hamlets. It is not a location where strategic-scale growth is appropriate. Small-scale housing for local community needs would be the right policy approach eg rural exceptions sites, community land trusts, limited infill or redevelopment of brownfield sites. The purple line on the map above shows the AONB boundary, Great Kimble within the AONB. Little Kimble is partly in the AONB. Smokey Row is near the AONB and on some footpaths which are important strategic green infrastructure links between settlements and the AONB (the North Buckinghamshire Way/ Midshires Way and the Aylesbury Ring), the views from these paths towards the AONB should not become urbanised (as in photo of the Chinnor example in our statement for Matter 8).